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xxx how SABMiller AvoidS tAx<br />
in developinG CountrieS<br />
The marketing of SABMiller’s beers is all about<br />
their national origins. Castle, now brewed in nine<br />
countries and sold in 40, is “South Africa’s national<br />
beer”. 37 Among the company’s four global brands<br />
are Grolsch – “a true Dutch beer based on a recipe<br />
and brewing secrets passed down from generation<br />
to generation”, 38 and Peroni Nastro Azzurro –<br />
“exemplifies the traditions of Italian craftsmanship,<br />
passion and flair upon which it was formed”. 39<br />
Yet for SABMiller, the reality is much more<br />
complex. British Grolsch drinkers are drinking beer<br />
produced by an American company, under license<br />
from a British multinational with South African<br />
origins. The rights to Castle beer are held in the<br />
Netherlands, while the Peroni brand is owned by a<br />
group company in the Isle of Man.<br />
Welcome to the brewing industry, 21st centurystyle,<br />
a world in which four massive conglomerates<br />
control almost half of global consumption, and<br />
make three-quarters of the profits. 40 It’s a world<br />
in which much of a company’s market value can<br />
rest on the value of its brands, yet this value can<br />
be totally divorced from the operation of brewing<br />
itself and squirreled thousands of miles away in<br />
a tax haven. 41<br />
fouR CoMPAnIeS ConTRol AlMoST A hAlf<br />
of globAl beeR ConSuMPTIon AnD MAke<br />
ThRee-quARTeRS of The PRofITS<br />
20 <strong>Calling</strong> time<br />
Multinational companies of this size are complex<br />
entities made up of hundreds of individual<br />
companies. It has been claimed that 60% of all<br />
world trade takes place between companies that<br />
are part of the same group. 42 These transactions<br />
play an important role, not just in distributing goods<br />
and services between group companies, but also<br />
in distributing profits and tax liabilities.<br />
Yet the system by which they are regulated<br />
provides ample room for companies to shift their<br />
profits away from countries in which they would<br />
incur a higher amount of tax, and towards those<br />
in which the liability is much lower, all without<br />
breaking the law (see Box 6). These payments can<br />
reduce or even eliminate profits in one place at a<br />
stroke of an accountant’s pen; a kind of financial<br />
alchemy that can also shrink a company’s tax bill.<br />
<strong>ActionAid</strong> looked at the accounts of a sample of<br />
eight SABMiller subsidiary companies across five<br />
African countries – Ghana, Zambia, Tanzania,<br />
South Africa and Mozambique – and India.<br />
Combined with research into the taxation systems<br />
of these countries, we were able to estimate<br />
the amount of tax the company saved in those<br />
countries through four different tax-dodging<br />
techniques. All of these techniques are based on<br />
payments – and therefore the transfer of profits –<br />
into tax havens.<br />
Breweries<br />
Bottling & desalination plants<br />
Tax haven subsidiaries