His deployment approach was not unusual: line and marketing managers in production and sales centres on each continent; lawyers in national capitals; financial front office in New York; administration in global shared services centres.

This disaggregation is challenged by national economies and borders. To sell products and services that governments buy, regulate or restrict and to pay income taxes, a ‘head­quarters’ needs to be named.


Most US headquarters are legacies; companies live where they were born. When the legacy location has problems or the company seeks a new path, making a location change is an investment in the new plan. Factors behind these moves are well known to fDi Magazine readers: talent, taxation, access to customers, operations, etc. And, since most large US enterprises earn at least half of their profits abroad, and many plan for more growth there as well, expect more ‘US’ companies to decamp to countries with attractive tax policies in addition to other key attributes.

Even very young US firms have global aspirations and some consider tax-advantaged headquarters from the outset. A no- or low-tax country boosts after-tax income and is reflected in their valuation. In a liquidity event, shares might be priced at a multiple of 10 or more times income. When tax savings increase the company’s valuation and lead to increased returns to management and early investors, the attraction is obvious.

Policy leaders seeking young and mature companies may find low taxation offers a path to growth. And, if they can recruit or keep the headquarters, maybe they will capture a few other functions as well.

Daniel Malachuk works with business and government leaders on global direct investment strategies. He has advised many of the world’sleading companies and served in the public sector as director of White House operations.