Vi lever i en moderne tid hvor våre rike forettninger og bedrifter gjør som de vil. Det er det ikke spørsmål om lengre. Det er til å forvente! Vi forventer at bedrifter og multi-nasjonale selskaper gjør akkurat som de vil. Det får de lov til fordi de er rike.
Hvorfor sier jeg, ikke fordi #PanamaPapers ble sluppet og det viser hvilke tekniker de rike bruker for å slippe unna skatt i hjemlandet. Man lager strå-selskaper i for eksempel Luxemburg under “Society Anonyme” eller S.A. som har en hemmelig avtale som kan gi opp til 70% av utbytte skattefritt, for så bare ta 10% av de resterende 30% av de pengene som er flyttet fra Norge til Luxemburg. Dette vil være som om man sender 100 Euro til en S.A. Da kan man ta ut 70 Euro uten skatt. Igjen av de 100 Euro er 30 Euro, av disse vil det bli 10 % skatt på og i realiteten 3 Euro av de 100 Euroene som ble sendt til S.A. Så det er greit å være rik og ha gode skatte advokter som kan ordne gode avtaler.
Du vet du er rik når du driver dagligvare kjeder som NorgesGruppen eller Reitan Gruppen. Dette vil være Kiwi eller Rema. Der de kan bryte reguleringer for åpningstider og arbeidstid bestemmelser uten å få annet enn kritikk. At ikke NorgesGruppen eller Reitan Gruppen får bot, bøter eller straff er fjernt. Men så er disse som er eierne så rike at de kan kjøpe seg makt. De har alle friheter og trenger ikke å tenke på hva de egentlig gjør. Fordi eierne er med eliten, de koser seg med champagne med eliten og har svære båter på fjorden når de har fri om sommeren.
At Rema bryter loven fordi de sier at NorgesGruppen bryter loven er ikke korrekt. Begge er feil for om jeg hadde brutt loven. Så hadde jeg hatt et problem og enten betalt bot eller brukt deler av min tid på en svært kjedelig glattcelle. Siden Rema-Reitan og konsernet Norgesgruppen og alle deres rike aksjonærer. Disse trenger ikke å bry seg. De tjener masse penger på selge Grandiosa og brød. Coop kjedene har ikke søndagsåpne, men hadde sikkert hatt om de hadde hatt mindre butikker etter Brustadbuene sitt reguleringer.
De kan i realiteten ikke bry seg om lovgivning og reguleringer siden de overseer den akkurat nå i mange butikker. Problemet er at om en liten butikk som ikke tilhører et konsern eller kjede så ville den fått en bot og straff som hadde stengt butikken. Alle var kjapp med å kritisere Lime for deres forferdelig drift og utnyttelse av arbeidskraft. Dette er ikke det samme, men fortsatt så er det brudd på regelverket vi har idag.
Regelverket vi har skal vel forsatt sette standarden for hvordan ting blir drevet? Eller skal vi være helt anarkistiske å ikke bry oss om de regler og lover som kongeriket har? Eller er det bare de rike som selger dagligvare som kan gjøre akkurat som de vil?
Kan de gjøre som de vil fordi vi har Brustadbuer, Narvesen/7-Eleven/Deli DeLuca som er automatisk åpne! Sammen med disse hage-forretningene som Plantasjen. Vi har jo også Statoil og Shell som også er åpne på søndagene. Så man kan enten gå på en kafe, kiosk eller bensinstasjon.
Disse rike kjedene og eierne får lov til å holde på som de vil. De er så rike at politikerne og ordførere er deres venner. Industri-herrer og matvareprodusenter er enten del-eid eller hel-eid av disse for å skape større avanse for disse eierne av hele kjeder og hele selskaper som Reitan, Norgesgruppen og Coop.
De burde jo være under samme regime som resten av oss. Som har måtte sende søknader for å sette opp uthus og garasjer. At vi må følge regelverket for å være lovlydige, det er det som er forskjellen på vi og de rike som disse aksjonærene eller matvarekjedene… De slipper unna og kan bryte loven uten straff. Det er heller ikke vært snakk om at ombud eller andre instanser setter igang med bøter eller straff av disse. Det er for en person som meg forkastelig og gjør at vi lever i en slik lovløshet. Ikke at vi lever helt i dette, men den arrogansen fra disse eierne som gjør litt som de vil.
Uansett om det er Reitan eller NorgesGruppen er det ett fett for meg. Begge burde få straff for å bryte med regelverket som handelsstanden har og de arbeidskrav som de ansatte skal leve under. De skal ikke la dette går utover sine staber og utover de lover som Matvarekjedene har for å kunne drive forretninger. Dette burde være selvsagt med avmakten og deres posisjon som selskaper vises frem i denne saken. At staten og styresmaktene lar dette skje uten å vise direkte kritikk eller noen form for straff er for meg fjernt. Siden alle andre som bryter loven og så åpenlyst pleier å fakket å få sin bot.
The Company in Scandinavia famous for getting George Clooney to be parts of their commercials and being synonymous with the Norwegian National Team of biathlon, making Ole Einar Bjørndalen wearing a Vital hat to the races and competition as a display of one of the main sponsors of the National Team. That is ordinary in sports, and is ordinary in the time we live in. So that a big bank is supporting a National Team is everyday event, but that is not what I will write about and discuss. As I got to read one of the papers in the Panama Papers leak. Here it is and hope you can see how DNB Nor ASA used the opportunities for meager taxation and higher earning for their subsidiary.
Before you continue her is a classy ad from the company:
Now we will see how the Norwegian Company can also be a little greedy and trying to avoid taxes in Norway, but still earning the profits and having accounts, but using the PriceWaterCoopers (PWC) offer for a Shell Company in Luxemburg to save taxes and still keep the funds in safety in Luxemburg. That is the grand DNB Nor who is the largest bank group in Norway.
Here is how they do it, and it is epic ways of using the shell-companies to avoid Norwegian tax regime and use a Corporate Fund that is a S.A. “Societe Anonyme” as financial company in Luxemburg to simply benefit from the specific tax status for a company in Luxemburg instead of the Norwegian one. Let me take you for a ride!
What is the Carlson Fund Management Company S.A.:
“Carlson is a Luxembourg resident company incorporated on August 14, 1990 as a limited company (“Societe Anonyme”) in order to develop the German and other European markets” (…) “Carlson is a company of DnB Nor group (hereafter the “Group”). The Group is Norway’s largest financial services group with total combined assets of NOK 1,834 billion. It includes strong brands such as DnB NOR, Vital, Nordlandsbanken, Cresco, Postbank.en, DnB NORD and Carlson” (…)”Carlson is part of the life and asset management branch of activities of the Group, DnB NOR Asset Management. It is Norway’s largest fund manager and has a leading position within discretionary asset management for institutional clients in Norway and Sweden” (…)”Until July 28, 2006, the purpose of Carlson was the creation, management and administration of a unique fund, Carlson Fund, created in Luxembourg on August 31, 1990. In this respect, based on the Luxembourg law on UCis, Carlson benefited from a specific tax status exempting the company from Luxembourg corporate income tax, municipal business tax and net wealth tax”.
You think that is saga in the making just see what more they did to secure lesser tax in Norway and close to none in Luxemburg, because corporate greed is what makes the world run like Ussain Bolt!
“By resolution of the Extraordinary General Meeting (“EGM”) held on July 28, 2006, Carlson has amended its by-laws in order to comply with the law of December 20, 2002 transposing the UCITS III Directive 85/611/EEC into Luxembourg law. Since the EGM, Carlson has been responsible for the management and administration of several investment funds. Carlson currently manages a portfolio of funds under 3 fund umbrellas: Carlson Fund, DnB NOR Fund and more recently DnB NOR Part II Fund since February l, 2008 (hereafter the “Funds”)” (…) “As from the date of the EGM (i.e. July 28, 2006), Carlson became subject to an unlimited tax liability and is considered as a newly incorporated entity for tax purposes”.
You think that is bad and telling how the Carlson entity of Luxemburg, which funds and fueling money from the DNB Nor and their subsidies and banks in Norway. As he Tax is high here for any profitable business, this kind of transaction and order clears lots of funds from the Company and banks, which gives higher profits, because of less tax as they follows through consultation to follow the exemptions laws in the tax-haven. Here we go!
How do they secure the tax-exemption with the laws in Luxemburg?
“Based on article 35 (4) of the Luxembourg Income Tax Law (“LITL”), when a company becomes taxable, all its assets and liabilities have to be valuated, at the time of the conversion, at their fair market value The assets and liabilities concerned are those “contributed” to the fully taxable entity, including intangible assets (article 59 (2) LITL)” (…)”the tax balance sheet has to take into account all the assets and liabilities of Carlson (i.e. the whole assets and liabilities whose, by nature, intend to serve the activity of the company2) including the valuation of the management contract. The administrative doctrine precises that is assimilated as an asset all the potential assets that can be exploited in the context of the activity of the company and with an individual economic value” (…)”Carlson has to revalue its capital in its opening tax balance sheet. The revalued capital includes the share capital of the formerly tax exempt company, the reserves accumulated by Carlson until the moment of the conversion, as well as the revaluation reserves resulting from the step-up at the moment of the conversion. The revalued capital is treated as “fiscal capital” in the hands of Carlson from a tax point of view. Any repayment (of part) of this “capital” to Carlson’s shareholders will therefore not be subject to withholding tax in line with the provisions of article 97 (3) b LITL”.
Now we have seen how the DNB Nord have put a S.A. Society Anonyme with the Carlson Funds to drop money into the Tax-Haven of Luxemburg as the DNB thinks the suits of Luxemburg to perfection and wondered if Barney Stinson bought suits made for Luxemburg.
DNB set up the Society Anonyme is set up with a new “EMG” to get unlimited tax-liability in Luxemburg. So the advice made the funds from the company under the Carlson from the time of the board-meeting by law of the 28. July 2006. The continued thing they did was to take their assets and monies fueled into the Carlson Funds, so the liabilities together with all of contracted value and management in the tax-balance sheet. So there fueling of moneys into the Fund is also fiscal capital and because of the status of the S.A. hide more in the secret company there.
Then the control of Carlson Funds is by all means controlled by DNB Nord as written here:
“As an example, a major part of the support activities (e.g. accounting) is done in close collaboration with the members of the Group located in Sweden/Norway. Moreover, the members of the team managing Carlson in Luxembourg are all senior officers originated from the Group. Consequently, the distribution of the Funds in Luxembourg is mainly performed thanks to the support of the Group”.
Here is what the group is supposed to pay in tax:
“Taking into account the total 2006 and 2007 value of the business compared to the total 2006 and 2007 annual profit before tax, Carlson will pay an annual and arm’s length remuneration in accordance with articles 56 and 164 (3) LITL to the Group for its support representing 65,92% of its annual profit before tax” (…) “Carlson will benefit from such retrocession of fees over a period of 10 years. As the taxable activity of the Company started in 2006, we propose to recognize such retrocession as from August I, 2006 until the financial year 2016” (…)”The computation of the percentage of notional retrocession of fees will be subject to a supervision period of 4 years (2006-2010). In case of significant/major changes in the business in Luxembourg, Carlson commits itself to inform the Luxembourg tax authorities of any significant changes that would modify its business and/or its tax position in order to agree on the more appropriate tax treatment”.
If you wonder what retrocession means that is planned underwritings of the earnings of the company. Underwritings or retrocession is usually a volunteer act of a company to return property or ceding property, though usually by request and not by forced transaction. Also the underwriting is also done to diversifying assets by consolidating them amongst the stakeholders. That means the last one the percentage of the company which is 65 % of the profits of DNB NORD’s Carlson Funds will dived 65% of the funds to the stakeholders of the company. Initially meaning that the Stakeholders or the Owners of the DNB NORD and that before any tax in Luxemburg, which is beautiful business model for the Stakeholders and for the ones owning DNB, and by literal controlling Carlos Funds.
The Company found another way to dodge a little more tax:
“Net Wealth Tax:As no intangible asset is recognized in the tax balance sheet of the Company, there is no increase of the unitary value of Carlson for net wealth tax purposes”.
This is initially saying that since they have not written any assets of value when they started to operate, therefore they does not have assets or monies worth to be classified for the Wealth Tax Purposes in Luxemburg. Here was yet another way of using the loopholes in Luxemburg to get even less taxation and a favorable way of using the tax-system there.
This article in the middle of the charter of Carlson Funds says the truth of the company:
“The purpose of the corporation is the creation, administration and management of one or several Luxembourg and/or foreign collective investment funds in transferable securities authorized according to the Directive 85/611/EEC, as amended (”UCITS”) and of other Luxembourg and foreign collective investment funds not covered by trus Directive (“UCI”) (all together the “Funds”) on behalf of their unitholders or shareholders in accordance with the provisions of chapter 13 of the Luxembow-g law of December 20, 2002 on undertakings for collective investment, as it may be amended from time to time (the “2002 Law”) , and the issue of certificates or statements of confirmation evidencing undivided co-ownership interests in such Funds. The corporation shall manage any activities connected with the management, administration and promotion of the Funds. It may on behalf of the Funds, enter into any contracts, proceed to any registrations and transfers in its nam~ or jn third parties’ names in the register of shares or debentures of any Luxembourg or foreign companies, and exercise on behalf of the Funds and the holders of certificates of the Funds, all rights and privileges, especially all voting rights attached to the securities constituting assets of the Funds. The foregoing powers shall not be considered as exhaustive, but only as declaratory”.
This here says enough of the practices of the Norwegian Banking group of DNB Nor or DNB Nord ASA had a subsidiary for recess their tax-operation and use the lucrative opportunities for keeping the profit without having issues with the Tax-regime in Norway. As the Norwegian rules and tax-regulation without studying them is stricter and has to be stricter than this. Because the end of the Tax contract with Luxemburg disclose the information where they are planning not to pay for their “Net Wealth Tax Due”. So even if the funds grow massively and the monies invested in the Carlson Funds, the opportunity to underwrite 65 % before the tax on its profit and that is possible with the “underwriting” method. In that sense the taxation of the will always is 10% on very little part of the funds, as the stakeholders can theatrically take 65 Euros on the 100 euros. Leave behind 35 Euros of it profit and pay 3, 5 Euro on the 100 Euros of Profit, that is a beautiful operations. If it wasn’t for the underwriting of the revenue then the company would have by the standard tax of Luxemburg paid 10 Euros of tax. 10 Euros is not much of a profit of 100 Euros, but still vastly more than 3, 5 Euros, the difference by quick calculation is 6, 5 euros. That is nearly a price of a Big-Mac Combo-menu that cost around 8 Euros in Luxemburg.
That is because of the technic of underwriting and sharing that with the shareholders and stakeholders of the Carlos Funds S.A. in Luxemburg which is their subsidiary. As written so nicely to the Luxemburg Department of Tax Collection in 2nd July 2008:
“on behalf of our client Carlson Fund Management Company S.A. (hereafter also referred to as “Carlson”), we respectfully request you to confirm, in writing, the content of this letter as to the Luxembourg tax treatment applicable to the situation described herein”.
That the Carlson was supposed to get the reasonable Tax Treatment for the company so there was a hashed plan from the get-go together with the Company of PriceWaterCooper. The plan was made an acted upon. This would not been possible if the DNB Nor did not use the guidance and setting up the charter after the laws there and follow the guidelines of the company setting it up for making sure of having less tax.
As explained with the 100 Euros scenario. The certainty is not any excuse from the DNB Nor can tell away. As they explained in 2016 to the Norwegian Press:
“No, DNB Luxemburg does not help the costumers to avoid tax. The Advisors function as discussion and talking-partners when it comes to financial questions, which offers legal and legitimate tax-plan for the costumers who live abroad. It could for example be about advice about financial-solution, cross-border transactions, complicated inheritance-regulation and other taxing environment that would be different from the ones who are living in Norway” (…)”DNB does not operate in Luxemburg because of taxation (Foss, 2016).
Well, I have already explained there operation and how they get to pay as little tax as possible through their operation. So DNB Nor had or still have the Carlson Fund Management Company S.A. in Luxemburg to save taxes and earn more monies in their operation and company there. Something they would be able to do in Norway or under Norwegian taxing regulation. Peace.
MF I/ECCi/ AEGN/C21108001 M-PEWR – “Carlson Fund Management Company S.A. – Identification tax number: 2006 2240 378- Recognition of a license fee for tax purposes” (02.07.2008) – PriceWaterCooper (PWC)
For those who have been surprised by the recent allegation and findings in the #Panama Papers that incites lots of politicians, the general elites and businessmen connected close to the governments. The money always talks, the money always moves and by any means possible.
For the wealthy and close connected they have the ability to forge networks and find businesses that earns coins on helping to move that money. But that is not for the ordinary people, as we pay a fortune to use RIA or Western Union to move between usually loved ones. But the Panama Papers are for whole other ordeal.
This here is for Tax Aviation’s and getting rid of extra burdens on the solid amount money they have gained. The persons and companies are set-up Shell-Companies to stack up money in British Virgin Island (BVI), Panama or Luxemburg. As this places doesn’t have that many inhabitance or sheep to earn money on, they earn tiny percentage on being “big-banks” for all kind of operations, while securing that the companies and persons involved can keep it discreet and silence. Until cover-ups like the recent ones shows the true color of the amount of money, that are dished away. The money that are stashed-away is millions upon millions of American Dollars; dipped away in a treasury chests that most economies would dream of having in circulation!
That should not be surprising as all of well-known government leaders are setting up and making it possible to have sophisticated economic systems that cross-borders for the benefit of trade; while these are used to ship the money from the places that have initially no taxes and programs that made up to build societies. This is also the places where they can have it without any concern, except some extra sunshine and a family resort at the beach, though I would not consider that in Luxemburg, unless suits and gas-stations are your thing.
The business-men and government officials, even relatives usually walks around with that without problems for decades as the banks, and the legal advocates set-up this fixed businesses to secure the fueling of their money. The worst thing is the loopholes and the ways that this decisive methods to undermine the local public to create and secure more funds for already wealthy clients. Where the bank as HSBC and lawyers of Mossack Fonseca divided fees to pocket the money that the client needed to send away from the shores and country-sides; where the money was raised and earned. While getting away from local agony of having fortunes and paying taxes on the high-incomes earned to the local communities.
If you we’re shocked of the values and the persons that was involved in the scandal of late, I wasn’t as the government officials, presidents sons and daughters; kin and other close connections have always gained extra through the cronyism or nepotism have been a thing since the Roman Empire, and does not stop any time soon. That the President Museveni of Uganda owns businesses and would have dashed a fortune for his grandchildren in an tax-haven through multiplied shell-companies. The same would not also be surprising on the Kenyan President Kenyatta who recently brought Sameer Diary and Livestock Limited who sells ‘Fresh Diary’ in Uganda through his company Brookeside. Surely his kins and family have some money abroad to secure in dire times might come. The same is certainly with President Kagame, who even been seen during the scandal that RPF-Elite men have been insiders in the scandal, as President Kagame have control and ease over it; surely he would skim over the top and gain some extra funds as the Executive. Similar is it in Democratic Republic of Congo where President Kabila sister is central profile in the scandal and shows how the monies and funds appear in tax-havens as she owns businesses and also the centralized economy around nepotistic and cronyism. Something that should not be shocking for anyone.
What this scandal shows is the amounts and estimates, this is through to major companies who serves this clients that are close by this totalitarian and big-men leaders who have close connected with central industries as they have to be granted and get contracts with government to drill oil, mining or even gain markets in the countries. With that power comes also embezzlement, kick-backs and percentage of the top that get skimmed through the advanced economic products that the blue-collar lawyers and bankers offers; they do that legally, but in a moral grey area as this thieving of government controlled funds in the name of the beneficiary or the shell-company in discreet secrecy. It’s not only dictators and their wives who are into it, I am sure if it wasn’t for the failed ‘Wonga Coup’ Mark Thatcher would still be up to game as the son-fallen from grace and proud family tradition; as even David Cameroon have been put into the mix. There is no shortfall when it comes to greed, and corporate greed never stops.
As the world leaders tries the best to hide their businesses and ownership through shell-companies and strawmen, or getting a cousin to run the business kind of like what Trump does to his son, just a little more subtle.
The governments are taking the sides of happy uncles as they all tries to open trades with tax-havens to keep businesses in their countries. The Companies who in many countries are seen as“Legal Person”can own land, own other businesses and be sued. Certainly with that power as stakeholders and shareholders does not care about other things than the bottom-line, they want to sell or sell enough services so that their earning a profit, by any means. That is why big businesses have been taken for tax-evasion in the UK this was Amazon and other online-retailers as they we’re officially legal unit in a tax-haven and not in the United Kingdom, though the products bought on Amazon was sent from a warehouse in UK, and sent to UK houses. The transaction between costumer who got the book from Amazon payed to a British account, but before the cash kissed the taxation to the Government of UK, it was sent to multiply Amazon shell-companies before ending at a Tax-haven. So that the United Kingdom get only pennies in tax compared to the Pound Sterling the UK state was supposed to earn from the Amazon LLC. That is just an example, but still important as a precise maneuvers the companies and international companies do, so they does not pay full-taxes or truthfully through sophisticated economic programs and revisions get the monies through foreign banks and tax-havens with help of legal teams in companies similar to Mossack Fonseca.
How to set up shop:
The LLC and Shell Companies will be used in market strategies as ghost straw-men for the owners sending monies through networks of intricate syndicates and money-laundering operations; That make Uncle Scrooge or Scrooge McDuck wishing he was a real person and not a cartoon character made up by Carl Barks in 1952; instead he is owning a Oil Company drilling oil in either Kazakhstan, Nigeria or North Dakota. Where he got the proceedings through UBS AG or HBSC; where the profit gets through manufactured holding companies and sent to BVI or Guernsey; where the McDuck Oil Company has headquarter, by official paperwork. That paperwork is written and made by lawful actions through Mossack Fonseca; while most of the Blue-Collar men are working in the unofficial Headquarters in the heart in the City of London or New York. But their taxing is little or near none there, because of McDonald Oil is fixed in Guernsey; Where they only have a Post-Box at the island; which by my reckoning would forward the mail to London or New York as the employees would actually be there.
This is a way of getting the bottom-line and the more of the ends directly to the stakeholders and owners of these companies tries to advance with this opportunities, that we the ordinary citizen, commoner, person or fellow human being would not be offered, since we don’t have the money to fix this or hire these men to forward our money, as we need the cash we have to get a home rent or buy, get food on the plate, pay electricity, airtime, taxes and then trying to get a chocolate bar once in a while. There is where we are. The once who was surprised about these papers have had too much faith in their rich, the elites and the once who has fortunes. They do not want to share that fortune that they have earned on our governments and our consumption; while trying to avoid giving something back to society, and giving the government more funds to develop the society the rich are doing business in. Peace.