Marchionne's Choice of Fiat-Chrysler HQ Weighs Political Realities Against Lower Taxes

TTAC Staff
by TTAC Staff

Now that Sergio Marchionne has succeeded in joining Fiat and Chrysler together, for his next act he’s planning on moving Fiat’s headquarters out of Italy. While such a move has tax advantages, it would present a political and public relations challenge for Fiat and Marchionne in their home country. According to Reuters, the new entity, dubbed Fiat Chrysler Automobiles, will be a Dutch-based company with a UK tax domicile, while shares are listed on the NYSE with a secondary listing in Milan.

Marchionne is aware that locating the headquarters outside of Italy, where Fiat has operated for 115 years and has received government funding, or outside the United States, where Chrysler was bailed out by the federal government, could make waves and there is the possibility that the Italian government might intervene. “I’ve seen weirder things happen,” Marchionne said to journalists at the recent Detroit auto show. “So I sincerely hope they don’t create obstacles.”

The deal for Fiat to take complete control of Chrysler after buying the UAW retiree health benefits trust’s stake in the Auburn Hills based automaker was consummated last week and the result is the world’s 7th largest automaker, holding brands that include ,Alfa Romeo, Dodge, Ferrari, Jeep and Maserati along with the two corporate brands.

Marchionne is emulating what he did when he spun off CNH Industrial from Fiat: register the group in the Netherlands with a UK tax domicile. Marchionne has previously said that CNH Industrial will be used as “one of the technical blueprints” for Fiat-Chrysler. CNH is registered in the Netherlands, tax-resident in Britain and traded primarily on the New York Stock Exchange, with a secondary listing in Milan.

Marchionne, who trained as a tax accountant before attending law school by training, will present his plans to the Fiat board of directors today. Publicly he has insisted that moving the HQ and listing on the NYSE reflect “access to funding” more than tax considerations, saying that profits are taxed where they are made with “no impact” on the Italian government’s tax revenue. Because of tax credits for previous years’ losses, Fiat will not have to pay domestic Italian taxes for years to come. Still, to reduce tax burden, manufacturers can adjust the amounts of total profit attributed to the production, export or sale of each vehicle in different countries.

TTAC Staff
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  • Adam Adam on Jan 29, 2014

    Oddly enough, I'll be visiting Turin in mid-February, and I had planned to check out some of the historical sites regarding the long history of the automobile there. On top of that I drive a Dodge. Small world I suppose.

    • Th009 Th009 on Jan 29, 2014

      Sadly, Fiat closed down the Alfa Romeo museum ...

  • Lou_BC Lou_BC on Jan 29, 2014

    @Omnifan - you misted the part where Marchione said "profits are taxed where they are made".

  • Oberkanone My grid hurts!Good luck with installing charger locations at leased locations with aging infrastructure. Perhaps USPS would have better start modernizing it's Post offices to meet future needs. Of course, USPS has no money for anything.
  • Dukeisduke If it's going to be a turbo 4-cylinder like the new Tacoma, I'll pass.BTW, I see lots of Tacomas on the road (mine is a 2013), but I haven't seen any 4th-gen trucks yet.
  • Oberkanone Expect 4Runner to combine best aspects of new Land Cruiser and new Tacoma and this is what I expect from 2025 4Runner.Toyota is REALLY on it's best game recently. Tacoma and Land Cruiser are examples of this.
  • ArialATOMV8 All I hope is that the 4Runner stays rugged and reliable.
  • Arthur Dailey Good. Whatever upsets the Chinese government is fine with me. And yes they are probably monitoring this thread/site.
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