2009年-普华永道全球_Pharma_2020_Taxing_times_-_Which_path_will_you_take__28页_1mb

Summary of "Pharma 2020: Taxing times ahead"

Core Content

"Pharma 2020: Taxing times ahead" is the fifth report in the PwC Pharma 2020 series, focusing on the tax implications of the evolving pharmaceutical industry. The report highlights the increasing pressure on pharmaceutical companies to adapt their tax strategies in response to a range of political, economic, scientific, structural, and social trends. It emphasizes the need for tax professionals to play a more strategic role in shaping the future operations of the industry.

Main Views

• Rising Corporate Tax Burden: Governments in industrialized nations are expected to increase corporate tax rates to address public deficits exacerbated by the global recession. This trend is likely to lead to higher effective tax rates (ETRs) for pharmaceutical companies.
• Global Tax Transparency Initiatives: There is a growing push for country-by-country reporting, which aims to increase tax transparency and reduce avoidance. This could lead to more scrutiny of multinational corporations and their tax strategies.
• "Green" Taxes and Environmental Regulation: The pharmaceutical industry may face additional tax pressures due to environmental regulations, such as carbon taxes and taxes on chemical use, especially in the EU.
• Competing Tax Incentives: Emerging economies are offering attractive tax incentives to attract R&D and manufacturing activities. Countries like China, India, and Singapore are providing significant deductions and exemptions to lure pharmaceutical companies.
• Shift in Business Models: The industry is moving towards more collaborative and outcomes-based models, which will have complex tax implications and require more integrated tax strategies.

Key Information

Political and Economic Factors

• Soaring Public Deficits: The global recession has led to large budget deficits, prompting governments to raise taxes and cut public spending. This will likely increase the tax burden on multinationals, including pharmaceutical companies.
• Tax Incentives for R&D: Many governments are offering tax credits and deductions for R&D activities. The US, EU, Japan, and others have significant programs to incentivize innovation.
• Corporate Tax Rates in G-20 Countries: Industrialized countries generally have higher corporate tax rates than emerging markets. However, the latter are increasingly competitive due to tax incentives and lower rates.
• Government Actions: The G-20 has pledged to crack down on tax havens, and the OECD has created a blacklist and grey list of non-cooperative jurisdictions. This signals a shift towards more transparent and fair taxation practices.

Scientific, Structural and Social Trends

• Changing Product Mix: The industry is shifting towards more specialized and personalized medicines, while generic manufacturers are expanding in primary care. This diversification affects how products are taxed.
• Emerging Markets Growth: These markets are becoming more attractive for pharmaceutical companies due to their potential for growth and tax advantages. However, they may also present new tax challenges.
• Bifurcation of Supply Chains: The global supply chain is becoming more complex and geographically dispersed, which increases the need for effective tax planning across multiple jurisdictions.
• Healthcare Payer and Provider Focus on Outcomes: Payers are moving towards value-based purchasing models, where payments are tied to treatment outcomes. This requires pharmaceutical companies to offer more integrated healthcare solutions, which may have different tax treatments.

Taxation of New Business Models

• Collaborative Models: Companies are increasingly collaborating with various stakeholders, including academic institutions, hospitals, and technology vendors. These collaborations may involve profit-sharing agreements and hybrid entities, which have complex tax implications.
• Outcomes-Based Healthcare: The shift from selling medicines to managing outcomes introduces new tax challenges, particularly in how services and products are taxed differently.
• Strategic Tax Planning: Companies must adapt their tax strategies to support new business models, including rethinking how they operate in different markets and manage cross-border transactions.

Implications for the Industry

• Increased Complexity: The industry will need to navigate more complex global tax arrangements, including permanent establishment issues and hybrid entity strategies.
• Need for Tax Strategy Integration: Tax professionals must understand the broader business context to help shape operations that align with new models and market demands.
• Geographic Considerations: While emerging markets offer tax advantages, companies must also consider political and economic stability, workforce availability, and intellectual property protections when deciding where to locate activities.

Conclusion

The pharmaceutical industry is facing a transformative period from a tax perspective. As governments tighten tax regulations and push for greater transparency, companies must adapt their tax strategies to remain competitive. This will require a more strategic and integrated approach, with tax professionals playing a vital role in supporting new business models and navigating the evolving global tax landscape.