Global brewer under tax lens

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Multinational brewer SABMiller will come under the close scrutiny of tax authorities in five African countries, including South Africa, next month.
Logan Wort, an executive secretary of the African Tax Administration Forum (Ataf), raised the issue yesterday at a tax summit arranged by Deloitte, without identifying the company. He said the decision to discuss the company’s operations followed a report by anti-poverty group ActionAid.
Wort said the five countries were South Africa, Zambia, Tanzania, Ghana and Mauritius. The latter all had bilateral tax treaties with South Africa.
In the report, which was released in November last year, ActionAid accused SABMiller of “dodging an estimated $31 million (R206m) of taxes in Africa and India every year – enough money to educate a quarter of a million African children“. The report referred to “tax avoidance activities, designed to comply with the letter of the law not break it, as in the case of tax evasion”.
ActionAid said it used the term to cover strategies that were “legally permissible but which ActionAid regards as ethically questionable”.
Nigel Fairbrass, a spokesman in London for SABMiller, said the ActionAid report was “poorly researched”. In a response when the report was released, SABMiller said the company did not engage in aggressive tax planning in any part of its operations. And it said the report included “a number of flawed and inaccurate assumptions”.
According to SABMiller, which has 16 breweries and 21 bottling plants in Africa, in the year ended March 31, 2010, the group reported $2.929 billion in pre-tax profit and group revenue of $26.350bn.
“During the same period, our total tax contribution remitted to governments, including corporate tax, excise tax, VAT and employee taxes, was just under $7bn – seven times (the amount) paid to shareholders.
“This amount is split between developed countries (23 percent) and developing countries (77 percent). In both Colombia and South Africa, we contributed over $1bn in taxation to each respective government’s revenues.”
ActionAid, however, said SABMiller avoided tax by holding valuable trademarks for African beers in Europe rather than in their country of origin. “The cost of using the trademarks helps eat into the profits in the African subsidiary, so less tax is paid there,” the organisation said.
The topic of Wort’s address yesterday dealt with challenges to African revenue administrations. Ataf, which now has 29 members, was set up in 2009 to help African countries strengthen their revenue bases through improvements in their administration systems.
Wort quoted research published in March last year by Christian Aid, on the losses to the developing world due to the mispricing of bilateral trade, a practice which enables companies to pay less tax by diverting income to low-tax jurisdictions.
Christian Aid, a relief and development agency, said mispricing caused a $1.1 trillion outflow from developing countries to the EU and US between 2005 and 2007.
Wort also quoted the 2010 Global Financial Integrity report, which said developing countries lost between $98 billion and $106bn a year – about 4 percent of their total tax revenue – due to false invoicing. Global Financial Integrity is a non-profit research and advocacy organisation.
Wort said, apart from “aggressive tax planning schemes” by multinationals, problem areas in Africa included politicians and high-net-worth individuals. And the large informal sectors in most African countries complicated the process of tax collection. Other challenges included high compliance costs and corruption.