Juncker qualifie la position luxembourgeoise d’erreur historique :
Sous le microscope des administrations européennes sept géants :
… sans oublier les bonus des banques d’investissement UBS et Deutsche Bank poursuivis par l’administration fiscale britannique :
If you have time – you might like to try to unravel the UBS & Deutsche bankers’ £40M bonuses tax case “complexity” – if you find the machinations too “complex”, ask a ten year old what was really going on:
The court focused on whether the huge bonuses paid in “shares or securities” were in fact “cash” to be taxed as normal.
I have not read any comments from the court or tax-collectors about the several sham brass-plate tax-haven companies inserted into the centre of these imaginative and creative self-invoicing documents. The transactions to and from these companies (“vehicles”) are entirely sham – and so illegal in the UK. Criminal fraud will have occurred on signing tax-returns, appointment of “arms-length” faux-owners and faux-directors, company minutes and audited balance-sheets.
For such “complex” schemes to work – we all have to pretend and have to applaud the Emperor’s New Clothes. It’s a damned silly and time-wasting way to run the world’s economy. It is time we all grew up.
Please note that self-invoicing from brass-plate offshore companies, especially with few or no staff to justify the reality of such invoices, was and is illegal in tax-law across the OECD. Creating such invoices is criminal fraud (in the US it includes the serious crime of “wire fraud” ). The crime occurs when officers sign misleading Balance Sheets and Tax Returns, or claim that faux directors are real directors, or that the self-invoicing transactions are “at arms length”; or on “commercial terms”. The corporate treasurers and bankers commit criminal offences when they approve payment of the self-invoices and transfer the funds. Where several officers and advisors are involved, it is “criminal conspiracy” which carries a long prison sentence – such as the jail term of Al Capone.
Tax collectors are usually satisfied to collect the taxes and rarely bring criminal charges – except in persistent cases such as ENRON – advised by Arthur Andersen. Clients can sue their professional advisors over failed schemes “which are of course all perfectly legal” (they are not legal in the OECD) and the advisors seek to recover their costs from their professional indemnity insurance PII. Even the best advised schemes fail when the detail is closely examined by honest Courts and judges who do not themselves use tax-havens
… et les rulings belges pour 35 grosses sociétés