PepsiCo, IBM sell bonds through Singapore to reap tax benefit

A POTENTIAL tax benefit is spurring United States companies including PepsiCo and International Business Machines (IBM) to sell bonds through their Singapore subsidiaries, fuelling a record surge of sales from borrowers in the city state.

The tactic can allow companies to deduct interest expense from their taxable income in both the US and Singapore. That double deduction means that effective borrowing costs – after taxes – can be materially lower than they would be with a bond issued in the US.

The mechanics of qualifying for the benefit are complicated and a rule that emerged from the Organisation for Economic Cooperation and Development (OECD) in December may wind up stopping firms from using the technique. But companies may be able to take advantage of it for at least the next three years.

As companies sell bonds, they are pushing debt sales volume from Singapore ever higher. Last year, corporates sold US$51.5 billion of notes from the city state, more than double the previous year and an all-time record. That mainly came from Pfizer’s sale of US$31 billion of bonds, one of the biggest corporate bond offerings on record, in May 2023 through a Singapore unit to help finance an acquisition.

The sales have continued this year: PepsiCo Singapore Financing sold US$1.75 billion of bonds earlier this month, and IBM International Capital sold US$5.5 billion of securities in late January.

A spokesperson for IBM declined to comment. PepsiCo and Pfizer did not respond to requests for comment.

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New global tax rates are taking shape through the OECD to ensure minimum tax corporate rates are levied globally. Singapore domestic tax law allows a company, including a local subsidiary of a foreign corporation, to deduct interest payments on debt from their taxable income in the nation state. At the same time, the US tax code might allow companies to deduct a foreign branch’s interest expense from its US taxable income. BLOOMBERG