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

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.