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Welcome to Basildon! The English town is nothing if not inviting on its website. Even so, its burghers may not have envisaged their conurbation as a tax haven. Yet this is where Italy's Fiat Industrial seems intent on basing its principal office once a buyout of minority shareholders in U.S.-based CNH Global is complete. The deal will create the world's third-largest maker of capital equipment, with a legal incorporation in Holland and a primary share listing in New York. But the prospect of it having a U.K. operating base and tax residency has thrown up a storm: the official corporate tax rate in Italy is over 30 per cent, while the U.K.'s is set to fall to 20 per cent by April 2015.

Politicians on both sides of the Atlantic, already agonising about tax practices by Apple, the low corporate tax rate in Ireland, and a reluctance by Luxembourg and Austria to sign up to anti-personal tax evasion rules, can add this to their list. And yet the notion is not quite as wayward as it seems. Like many big manufacturers, FI/CNH stems from decades of consolidation, with former parents ranging from Sperry Rand to Ford. It will have 64 plants globally – one in Basildon – and no obvious national "home." True, the mooted structure hardly reinforces Fiat boss Sergio Marchionne's quest for simplication. But investors may not complain: FI shares rose 2 per cent on the possible tax treatment news.

Whether such forum shopping is right, from society's perspective, is another matter entirely. But devising a system to close it off may remain elusive. Even Brussels' dream of a "common consolidated corporate tax base" for the European Union is so complex that efforts would doubtless be made to game it. And politicians do tend to whinge loudest when somebody else is winning. You may not hear the U.K. – which relaxed tax rates and rules under competitive pressure to attract HQs – complaining much about Basildon's new status.

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