In March 2020 Ethical Consumer viewed P&G's US Securities and Exchange Commission filing Exhibit 21 for the financial year 2017-18, which listed the company's subsidiaries. P&G had multiple subsidiaries in jurisdictions on Ethical Consumer's list of tax havens at the time of writing. Of these, several were holding companies or financial companies, which were considered high risk company types for likely use of tax avoidance strategies:
Gillette Holding Company LLC - Delaware
Phase II Holdings Corporation - Delaware
Gillette Latin America Holding B.V. - Netherlands
Procter & Gamble Amazon Holding B.V. - Netherlands
Procter & Gamble Brazil Holdings B.V. - Netherlands
P&G Hair Care Holding, Inc. - Delaware
Procter & Gamble Finance Management S.a.r.l. - Luxembourg
Procter & Gamble Financial Services S.a.r.l. - Luxembourg
P&G had published a its 'Core Tax Principles' on its website. The summarised principles were:
- Tax follows business substance
- Highest level of compliance with financial and tax reporting requirements
- Robust tax stewardship and governance
- Transparency in relationships with governments and tax administrations
- Support for efficient, consistent, and administrable tax and trade policies
The company made no clear statement which explicitly mentioned tax avoidance or tax havens, nor did it explain the existence of a number of holding companies in countries considered by Ethical Consumer to be tax havens. P&G also did not publish country-by-country financial information.
An internet search using the search terms “[company name] tax policy statement country” found no country-by-country financial information or reporting (CBCR), nor clear public tax statement confirming that it was this company’s policy not to engage in tax avoidance activity or to use tax havens for tax avoidance purposes.
Overall P&G received Ethical Consumer's worst rating for likely use of tax avoidance strategies and lost a whole mark under this category.