The US pharmaceutical company Modern, producer of one of only two Covid mRNA vaccines currently approved by the world health authorities, it will use its own branch in Switzerland and another in the US state of Delaware to pay less taxes on the sale of serums against the Coronavirus. Everything perfectly legal.
The complaint comes from a Dutch NGO, the Research on Multinational Corporations (SOMO), which in a report published yesterday speaks of an alleged “triple whammy”Of the American company to taxpayers, accused of using“ tax havens ”such as the Swiss Confederation and the American federal state.
According to the nonprofit, Modern it may be able to pay less tax on its profits vaccines in Europe and on patents deposited in United States, having received instead huge public funds to develop your own anti-Covid serum, however, sold at prices that are anything but calm.
Primarily, SOMO quotes the first of the two contracts concluded between the US pharmaceutical company and the European Commission: the document provides that theUnion pay the doses ordered to the US multinational at the company’s Swiss branch, the Moderna Switzerland GmbH, made up only in June 2020 and with registered office in Basel. The Dutch NGO points out the “extremely low” level of the taxation on the income of foreign companies applied in Switzerland, equal to 13 percent.
The US pharmaceutical company produces its own anti-Covid serum through the Swiss subsidiary Loin, and for the doses intended for United States operates from a production plant located in Portsmouth, in New Hampshire, while carrying out the loads purchased byEuropean Union in the plant of Visp, in the region of Canton of Valais, in Switzerland, and in another in the Brightlands Campus of Geleen, in Netherlands.
At the beginning of June it was the same Swiss company ad to announce that the Dutch plant will produce up to 300 million doses per year Spikevax vaccine of Modern, thus becoming the main supplier of this serum forEU. It is also true that the decision to produce moles Netherlands the Covid vaccine of the US company is subsequent to the conclusion of the contract with European Commission quoted by the Dutch NGO.
However, “following the logic of fiscal justice”, according to SOMO, “The profits of Modern should be taxed where its real economic activity takes place to develop, produce and market i vaccines“. In fact, the non-profit proposes to make the multinational pay the taxes provided for in the Netherlands on the profits generated by the sale of the doses produced in the Dutch factory. In this case, the company should pay the 25 percent tax on its profits instead of the 13 percent applied in Switzerland.
Second SOMO, “it is likely that“About 8.7 billion euros to date owed to the company by the Member States ofEU for 460 million doses you order of Spikevax vaccine, Modern will pay off on average less taxes than it would have paid out if it had been subjected to the tax rates provided for in individual countries.
Not only. There Research on Multinational Corporations (SOMO) remember how the US pharmaceutical company holds “many of its patents” in Delaware, where is it patents, patent applications, brands, trademarks, Intellectual property and other similar kinds of intangible assets I’m exempt from state taxation if they constitute the main business of the company or branch registered there, just as in the case of Modern.
In addition, the multinational has received huge public funds, especially give it United States, to develop your own anti-Covid serum. According to US Department of Health, from December 2020 Modern got approx 4.1 billion dollars of federal funds to accomplish the Spikevax vaccine, of which 955 million only from the program Warp Speed, a public-private partnership set up by the president’s administration Donald Trump.
Despite this, the company has not at all calmed i prices. To date, Washington has nearly ordered 7.5 billion dollars of vaccines anti-Covid produced by Modern, paying approx $ 15 a dose. L’European Union he ordered over instead € 8.77 billion of serums Spikevax, by paying an initial deposit of over 300 million euros, at the price of 18 dollars (14.70 euros) per dose for the first order of 160 million vaccines and 22.50 dollars (about 19 euros) per dose for subsequent loads.
According to the calculations of the Research on Multinational Corporations (SOMO), about 44 percent almost 10.35 billion dollars (€ 8.77 billion) obtained by the American multinational from the sole sale of Covid vaccines in Europe “Will likely consist of profits“, Mostly taxed in Switzerland at a rate not exceeding 13 percent. According to Belgian business newspaper De Tijd, the company could even pay only the 7.83 per cent of tax on profits if it were to be subject to the Swiss regime envisaged for holding companies.
“The fact that Modern is willing to receive the proceeds of the Covid-19 vaccine in this branch (of Basel – ed) recently established, in a jurisdiction in which it did not previously have a significant economic presence, indicates that this move was motivated from a fiscal point of view ”, concludes the Dutch non-profit.
At the moment the company has not wanted to comment on the report of the Research on Multinational Corporations (SOMO).