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Perrigo agrees €300m settlement of €1.64bn tax assessment

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Over the counter drugs company Perrigo has settled the largest tax bill ever issued by the Revenue Commissioners for €297 million. When credit for certain taxes already paid is factored in, the cash payment that Perrigo will make will be €266.1 million, according to a filing with the Securities and Exchange Commission in the US.

The figure is just a fraction of the €1.64 billion bill the Revenue initially levied against the company which is headquartered in Ireland but operates out of the small Michigan town of Allegan.

Revenue had already accepted earlier this summer that the contested sum was just under €1 billion – at €976 million – following discussions between the two sides.

In an announcement after US markets closed on Wednesday, Perrigo said it was glad to put the uncertainty behind it. The Revenue assessment had been hanging over the company since 2018.

The company said it did not have to pay any interest or penalties on the disputed sum as part of the settlement.

For the exchequer, it is a significant boost at a time when Minister for Finance, Paschal Donohoe, and the Minister for Public Spending and Reform Michael McGrath are trying to balance their budget figures.

Contested transaction

Perrigo chief executive Murray Kessler said the company was still confident in its original interpretation of the contested tax transaction. However, it made sense for the group, its staff and its shareholders to agree a reasonable settlement and allow both sides to move on.

Mr Kessler has been leading a radical reshaping of the business and the Revenue assessment was, in his words, the final unresolved issue hanging over the group. He called it a “distraction” and blamed the uncertainty surrounding the group because of the scale of the tax assessment as a factor holding back the company’s share price.

The disputed tax bill relates to the sale by Irish pharma company Elan of its intellectual property interests in multiple sclerosis drug Tysabri in 2013 to Biogen for an up-front payment of $3.25 billion and a share of future royalties. That sale took place months before Perrigo bought what was left of Elan.

The row centred on Revenue’s decision, following a 2016 audit, to characterise Elan’s sale of Tysabri as a capital transaction, subject to tax at 33 per cent. On that basis, Revenue said €1.64 billion was owed and issued a Notice of Amended Assessment. The company maintained that the cash received was properly declared as trading income, taxable at 12.5 per cent under corporation tax.

Overstated

Revenue accepted in July of this year, without backing down on its view of the deal as a capital gains transaction, that the original figure it had assessed was overstated.

This was due in part to Perrigo not receiving $400 million expected under the terms of the Tysabri deal because the drug had not hit subsequent sales targets. Revenue also agreed that a capital gains tax interpretation of the sale would allow Perrigo set substantial expenses against the reported gain.

Perrigo was heading for a hearing of its case by the Tax Appeals Commission, where its original €1.64 billion bill accounted for a majority of the €3 billion at issue in the 20 largest cases before the commission.

Only Apple has ever faced a larger tax bill in Ireland but its contested €13 billon charge was handed down by the European Commision.

Mr Kessler has always said that he believed a resolution of the impasse would be good for Perrigo and good for Ireland.

Speaking earlier this year to The Irish Times, he said the tax dispute was affecting plans for the comapny to invest further in Ireland.

“I want to invest more. I have plans to invest more in Ireland. People ask me all the time: ‘Are you pulling out?’ We’re not pulling out, we want to invest more but we have to get it to a friendlier environment.

“If we didn’t have this battle over the last two years, we would be trying to find ways to put more things in Ireland to get more benefit. Because we are not really taking advantage of the structure.”


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Amanda Holden puts her five bedroom Surrey home on the market for £5million

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Amanda Holden has put her Surrey mansion on the market for £5million after giving the luxurious property a showbiz makeover.

The Britain’s Got Talent judge, 51, is hoping to make a £1.5million profit having splashed out £3.5m on the five-bedroom home seven years ago.

The detached home boasts its own bar, huge 30ft by 27ft living room, stylish kitchen diner and a hot tub, where Amanda has posed for several bikini pictures she’s posted on her Instagram page.

Amanda Holden (pictured) has put one of her family homes on the market seven years after she bought it for £3.5million 

The star often posts pictures on Instagram of her beautiful home, which she has been given a fabulous renovation by the star

The star often posts pictures on Instagram of her beautiful home, which she has been given a fabulous renovation by the star

The huge open-plan living room also displays eye-catching artwork, including a giant painting of a female astronaut and a £30,000 drawing by the Connor Brothers of a sultry woman in a silver dress smoking a cigarette

 The huge open-plan living room also displays eye-catching artwork, including a giant painting of a female astronaut and a £30,000 drawing by the Connor Brothers of a sultry woman in a silver dress smoking a cigarette

A source said: ‘Amanda loves her family home and is really proud of the work she’s done on it.

‘She’s had a real hand in the makeover and has enjoyed seeing her ideas come to life.

‘It will be a sad day when she moves out but Amanda can take comfort in the number of memories she’s created there.’

Amanda lives in the property with record producer husband Chris Hughes and their two daughters Lexi, 16, and Hollie, 10. 

After buying the home in 2015, herself and Chris described the mansion as their ‘forever home’ and Amanda admitted ‘badgering’ its former owner to sell it to them for years until they finally relented.

The couple also own a holiday home in the Cotswolds, which they have been renovating over the past year.

Heart FM DJ Amanda has spoken of her love of interior design

Heart FM DJ Amanda has spoken of her love of interior design

Amanda recently added a glamorous outhouse to the Surrey property where another bar and the hot tub are located, set upon a large wooden decking area, close to a palm tree she planted in honour of Sir Captain Tom Moore.

The garden room also includes a log burner and comfy sofas, which Amanda says are perfect for a ‘sneaky afternoon disco nap.’

The Heart FM DJ renovated her bespoke Wilson Fink kitchen during lockdown, adding new cupboards and worktops, plus mirrored tiles on the walls.

She also has three disco ball-style lights, worth £850 each, hanging over her breakfast bar.

And her quirky taste is exemplified by pineapple-themed accessories dotted around the property, including dark navy and pineapple-print wallpaper and a £125 Graham and Green pineapple lamp.

The huge open-plan living room also displays eye-catching artwork, including a giant painting of a female astronaut and a £30,000 drawing by the Connor Brothers of a sultry woman in a silver dress smoking a cigarette under the caption ‘If you haven’t got anything nice to say come sit next to me.’

The mansion, which includes five bedrooms, three bathrooms and a study, is located behind two sets of private gates which lead onto a private road towards the house.

The driveway is big enough to hold several cars, which is convenient when Amanda hosts her showbiz parties.

Speaking about her home to House Beautiful, Amanda revealed it was important their Surrey property didn’t feel like ‘a show home’

She said: ‘We have two little girls and don’t want them feeling that they’re treading on eggshells.’

Amanda’s passion for interior design has led to her landing a new TV show with pal Alan Carr in which the pair be doing up a property in Italy.

The series will air on the BBC after she pitched the idea to the broadcaster.

Amanda admits herself and husband Chris have so many clothes, they turned a room into a walk-in wardrobe – inspired by her favourite TV show.

She says: ‘I’m a huge Sex And The City fan and Chris did a Mr Big and turned a whole room into my wardrobe.

‘Except, he didn’t leave a pair of Manolos at the end… but he arranged everything else. It’s something I’ve always dreamt of.

‘There’s a remote-controlled mirror that goes up and down and lights up – it’s amazing.’

The star has taken to Instagram and posted photos of her on dreamy summer evenings relaxing her garden which includes a hot tub set upon a large wooden decking area, close to a palm tree she planted in honour of Sir Captain Tom Moore

The star has taken to Instagram and posted photos of her on dreamy summer evenings relaxing her garden which includes a hot tub set upon a large wooden decking area, close to a palm tree she planted in honour of Sir Captain Tom Moore

Speaking about her efforts to lovingly renovate her home, house proud Amanda explained: 'I am house proud, but I've got two kids, two dogs and a cat, so it's a family house. Everything is washable and wipeable.'

Speaking about her efforts to lovingly renovate her home, house proud Amanda explained: ‘I am house proud, but I’ve got two kids, two dogs and a cat, so it’s a family house. Everything is washable and wipeable.’

The buyer lucky enough to be able to afford Amanda's sprawling home will be able to relax in this stunning stand alone bath

The buyer lucky enough to be able to afford Amanda’s sprawling home will be able to relax in this stunning stand alone bath

The en-suite bathroom is just off the master bedroom where Amanda has frequently posted enviable pictures on her socials

The en-suite bathroom is just off the master bedroom where Amanda has frequently posted enviable pictures on her socials

And the TV favourite also concedes she’s a clean freak, meaning every service on the ground floor can be wiped fresh.

Speaking to The Mirror, she explained: ‘I am house proud, but I’ve got two kids, two dogs and a cat, so it’s a family house. Everything is washable and wipeable.

‘It’s so open plan my littlest can cycle her bike around. ‘I don’t have carpets on the ground floor – and this is disgusting – but I was doing an interview a while ago and my puppy pooed on the floor during the chat.

‘But you don’t worry if you have wooden floors. Two words: wipe clean.’

Amanda, who designed a homeware range for shopping network QVC, is so into interior design she believes it could eventually become a day job – if she ever loses her looks.

She added: ‘I want this to be a legacy. When my face falls off and all the telly work dries up, this is actually where I want to be.’ 

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Russian TV host refuses to apologise for report on mock nuclear attack on Ireland

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The Russian state television host who broadcast a graphic of a simulated nuclear attack destroying Ireland has rejected a request from Taoiseach Micheál Martin to apologise for the programme.

In a follow-up report broadcast on state-owned television channel Russia-1 on Sunday night, television host Dmitry Kiselyov refused to apologise for the animated graphic broadcast earlier this month showing a nuclear strike off the Irish coast erasing Ireland and Britain from the map.

On Sunday’s programme, Kiselyov, a Kremlin supporter and state propagandist, described Ireland as “collateral damage” in a potential nuclear attack by Russia on the UK in any escalation of tensions between the countries over Russia’s war on Ukraine.

While distinguishing between Ireland, a neutral country, and the UK, Kiselyov repeated the assertion in the original report that “the whole British archipelago was basically a sinkable island” and that Russia has “every capability for such a nuclear retaliation”.

Referring to Irish political and public reaction to the original report broadcast at the start of this month, the Russian TV host said: “Ireland literally flew into a rage. Of course as a neutral country, it wasn’t nice for Ireland to become collateral damage in Britain’s clash with Russia.”

The news report, according to a translation tweeted by the BBC digital journalist Francis Scarr who monitors Russian state television, quoted the Taoiseach describing the Russian media report as “very sinister, intimidatory tactics by the Russian Federation”.

“I don’t think anyone’s going to be intimidated by it. I think it reflects a mindset that is worrying and not in touch with reality. I think there should be an apology forthcoming,” the Taoiseach was quoted as saying on the Russian programme against a photograph of Mr Martin.

Kiselyov said he completely agreed that an apology should be forthcoming but that it should come from British prime minister Boris Johnson, falsely claiming that the UK leader had made a “groundless threat to strike Russia” that had led to the original report and simulated attack.

“But we’re not intimidating anyone. Talking about capabilities has an anti-war modality. As they say, let’s not start. It will end badly. It’s better to live in peace,” said Kiselyov.

Fianna Fáil MEP for Ireland South Billy Kelleher said the Russian state-owned station still owed an apology to the Taoiseach and the Irish people over the report and mock attack.

He described the Russia presenter as “a mouthpiece” for Russian leader Vladimir Putin and that “anything said by him were effectively the official views from the Kremlin”.

“It shows how delusional their foreign policy is. It shows how removed they are from understanding what neutral countries are,” he said.

“It is indicative of Russia’s view of the world and how they believe they can obliterate a nation if they feel that is necessary to protect themselves even if there is no threat coming from Ireland.”

The reports on the Russian national broadcaster were “outrageous”, “completely unacceptable” and “indicative of the delusional state of the entire Putin regime,” he said.

“We simply cannot have what are official media outlets relaying huge threats to wipe Ireland off the face of the earth, a neutral country that has never once threatened Russia,” he said.

Labour Party foreign affairs spokesman Brendan Howlin TD described the host’s comments as “both delusional and menacing on a number of fronts”, including how the television station was conflating Ireland and Britain.

“Ireland is a neutral country but as the people of Ireland have very ably demonstrated in the last two months, we are not neutral in relation to the illegal and immoral assault on the people of Ukraine by Putin,” he said.

“We will not be intimidated by grandiose, farcical threats emanating from Russia. This is not a comic book; this is a painful reality for millions of Ukrainians.”



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Sirius Real Estate sells London business park for €18.8m (GB)

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Sirius Real Estate has agreed to the sale of an asset in Camberwell, London, for €18.8m (£16m), representing a NIY of circa 2%. The property formed part of the portfolio Sirius acquired in November 2021 with its purchase of BizSpace, the leading provider of regional light industrial, workshop, studio and out of town office units across the UK. The sale price represents a 94% premium to the valuation at the time of Sirius’ acquisition of BizSpace.

 

The multi-tenanted business park, which comprises approximately 34,700ft² of industrial and office space is 91% occupied following a series of asset management measures delivered through the BizSpace platform. The sale is expected to complete in July 2022.

 

Commenting on the transaction, Andrew Coombs, Chief Executive Officer of Sirius Real Estate, said: “This disposal is further proof of the latent value in the BizSpace portfolio we acquired late last year, the price being significantly ahead of last September’s valuation on which our purchase was based, and the attractive sale follows our recent announcement that we had since improved like-for-like rental income across the portfolio by 7.5%. The sale will allow us to invest in new opportunities for BizSpace in the UK as we continue to build our acquisition pipeline. Bringing together the Sirius and BizSpace platforms, with a strengthened management team at BizSpace, is already delivering strong results and operational synergies that will enhance our UK portfolio.”

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