Henderson Diversified Income Limited is mulling a change to its corporate structure (currently it invests through a Luxembourg subsidiary). Since it was launched, there have been a number of developments in Luxembourg tax legislation and practice, in particular in relation to transfer pricing. The OECD has recently introduced the BEPS (base erosion profit shifting) framework under which over 100 countries are cooperating to try to reduce tax avoidance through transfer pricing.
The Board of Henderson Diversified Income and its advisers have continued to review these developments and have recently concluded that the company’s existing structure may involve increased complexity and risk.
Accordingly, the Board is exploring the possibility of simplifying its tax structure by electing to join the UK investment trust company tax regime, including changing its place of incorporation to the United Kingdom. It is likely that any such change would involve the establishment of a new UK company and the liquidation of the Company and its Luxembourg subsidiary and would lead to a reduction in annual running costs. The Board would not be proposing any changes to the investment management arrangements.
The Board will only recommend this change if it believes it to be in the best interests of shareholders as a whole and expects to update shareholders later this year.
HDIV : Henderson Diversified may move onshore