Pushpay (ASX:PPH) internal restructure to transfer IP from New Zealand to USA

• Pushpay (PPH) intends to enter internal restructure to transfer intellectual property from a New Zealand Pushpay subsidiary to its US subsidiary
• The company says the intellectual property was developed during the company’s initial years helping to form the foundation of the company
• Pushpay says in recent years 98 per cent of its operating revenues have come from the US, in turn progressively shifting the location of the company’s management and support from New Zealand to the US
• The financial consequences of the IP transfer are expected to reduce the company’s income tax expense of greater than $10 million annually, primarily due to the tax treatment of IP in the US
• PPH was trading 0.42 per cent lower at $1.18

Pushpay has announced the Pushpay group of companies (the group) is entering an internal restructure in which it will transfer intellectual property from a New Zealand subsidiary to a US subsidiary.

The company says the intellectual property has been developed during Pushpay’s initial years, helping to form the foundations of the Group.

Pushpay says in recent years 98 per cent of the group’s operating revenues has comes from the US, in turn progressively shifting the location of the group’s management and support functions from New Zealand to the US.

This shift has required the group to transfer its intellectual property from a New Zealand subsidiary Pushpay IP Limited to a US subsidiary, Pushpay USA Inc.

Pushpay says it’s engaged the New Zealand Inland Revenue via a lodgement application for a binding ruling on key aspects of the transaction and remains committed to meeting its tax obligations.

Financial consequences of the transaction are expected to reduce the group’s income tax expense of more than $10 million annually, primarily due to the tax treatment of intellectual property in the US.

Pushpay says the transaction is a non cash consideration by way of a share transaction between subsidiaries, meaning no external funding is required.

Subject to final bank approval, the transaction is expected to be effective within the next few months.

Pushpay Holdings were trading 0.42 per cent lower at $1.18 at 3:24 pm AEST.