Don Museveni says “I would never accept these foreigners to give me orders about Uganda”; Time to cut the direct donor assistance to the government budget of Uganda and after that let Don Museveni eat alone!

“I wouldn’t ask these foreigners, but I would never accept these foreigners to give me orders about Uganda. Or about anything in the world! They got their own countries to run. Let them go and run them. Uganda is ours. Nobody gives us orders here” – President Museveni at Kololo Independence Grounds Speech while celebrating the “Double Victory” on 9^th April 2016.

Now that it is not long ago he told the world that Uganda was his playground and he could shot and kill opposition because they had no place in his country. From the same man and leader comes this. Let me ask the international community to react to violent behavior and the aggression this President shows his own county.

The racketeering of the NRM and their Executive has to stop at one point. That can happen when the funds dry up and the ammunition does come with the next boat. The American should stop with their alliance and their UPDF trainings. The Americans should do as they did with the MCC in Tanzania; suspend the projects and direct-donor aid to budget funding of the Ugandan Government.

The French should stop supporting the Government projects in Northern Uganda and cut their loans as they have promised to effect directly the RDC and the other loyal cronies of Northern Uganda. This does so the Capos of the Don get their monies and keeps eating. While the Japanese should stop supporting infrastructure projects together with the Chinese Foreign Ministry, while the CNOOC should terminate their contract with the Uganda Government. Total Oil firm of the French should suspend their operation until the government accept their blood-money. The Same with Heritage Oil for Britain so the UK Gov. should disband their direct government support and take away the incentive from UK to Uganda. The Norwegian Government should suspend the Oil for Development Program that have been a steady program since 2006. Because if you hurt it where it could become most important, then the Don Museveni might listen.

The European Union should to hurt the Foreign Exchange rate suspend the import of Robusta Coffee beans from Uganda, as the export of this is a major factor in the economic trade in the land-lock country. “A total of 271,941 bags of coffee valued at US$ 25.12 million were exported in February 2016 -Source UCDA report”. If you want to hit where it hurts, then you take away the foreign exchange and the foreign exports. This here could really hurt the government that does not want to have any interference or questions about their rule.

If the Donors and giving aid, would suspend or cut the services for the Peacekeepers, the same reaction that the Dutch did with the Burundian Peacekeepers in the AMISOM in Somalia. The same could be done by the American Government and EU as they are the major benefactors for the economic spending ground and facilitators for it.

It is not like I am for neo-colonialism, but when a totalitarian and gangster like Don Museveni complains about the US Mission questioning his oppressive behavior and European Union saying their opinion on the display of character showed during the Election and announcement of the results. Then it seems like he does not need any-more international legitimacy for his rule. Only their money and aid when it comes in handy too fuel money to a private plane, refurnishing the State Houses, buying new cars and more estates. Especially considering in FY 2013/2014 the donor assistance of the total budget was 21 % of it. Therefore the USAID, World Bank, IMF, DFID, European Commission, Irish Aid, NORAD and the other contributors should suspend that for the coming financial year of FY 2016/2017. To not hurt the citizens do this instead!

They should support the IDP camps and refugee camps in the Ugandan country through United Nations programs and organizations, build stronger relationship with NGOs in Uganda and forge good governance programs instead of supporting a government who is carrying out rigged election and embezzlement of government funds and international aid. Therefore progressive use of the tax-payers money from the Western Hemisphere, and if that is not working then, use it instead on local infrastructure projects to their own tax-payers.

Especially when a specialized report on Donor Aid to Ugandan Government says this:

“Budget support has not helped much in relation to cross sectoral dialogue. Some improvement was realized in education sector as dialogue with Ministry of Local Government and Ministry of Public Service improved. But this has not happened for the health sector” (…)”The power relations between bilaterals and Global Health Initiatives including PEPFER, Global Fund, GAVI, Stop Malaria etc shifted in favour of the latter who had no experience in the development of the budget support process and completely ignored to an apparent ineffectiveness” (…)”Budget support resulted in a greater commitment and quality of dialogue on PFM issues, especially after 2007 with the launch of FINMAP and JBSF. The influence of performance measures on sector dialogue declined from 2011/12, as the link with releases became less clear” (Joint Evaluation of Budget Support to Uganda – Final Report – 2015, P: 132).

This here proves the values of the Donor-Funding and the Budget Support from the International community to the Ugandan Government and the NRM-Regime. The NRM mafia under Don Museveni who says that the Ugandan authority do not want to have internal interference and foreign people questioning his playground. Therefore the authority and the Don want to rest things into peace he lets the people end up resting in peace. As he takes the Army and Police to detain the ones it needs and use draconian laws to oppress his own people.

Therefore with also the fraudulent election to keep the NRM mafia in order and also silence the opposition; as it even did yesterday the 9^th March 2016 with the Military Police taking over the Nakivubo Settlement Primary School so the “Victory Celebration” that was supposed to be held there with Lord Mayor Lukwago and FDC Leader Besigye. This happen while the Crime Preventers, NRM Diehards and the new MPs we’re celebrating at Kololo Independence Grounds while costing the 1, 5 billion shillings. The racket also carries to pay their own and let the kingpin eat the money alone. As he has done since 1986 and the donor have continued to fund the budget support and give Don Museveni money to do his bidding.

Therefore I ask the governments to question if they want to deliver more money the NRM Mafia who uses monies to the army and police, squander away State House money on funding his campaign and also rumors of AMISOM contingent. There are certain numbers on his spending on military is staggering over the years. In between 2011 and end of term 2016 the taxpayers and donor-funding the total Shs. 6.617 trillion to the Army, Police and Intelligence Agencies. Of this in MPS in February 2015 into the portfolio of sophisticated military equipment there was the extended use of Shs. 470 billion, alone that year.

So with that knowledge and knowing the international donors should consider some reactions as he does not accept any interference not internal and not external. The Playground might be for the moment him, the Don Museveni has spoken of killing demonstrating citizens and opposition. The harassment of the ones that question the power of the kingpin!

That is when the international donors in the powers of US Mission in Kampala and their Amb. Malac recently; and also when the European Union does state the fact that the election was not free and fair. Therefore the Don Museveni feels betrayed as this has been loyal men who have given money to his government and not question his power or rule. Because they needed him to do their dirty-laundry and also have a steady ally in the East Africa; as the US have a relationship with Ethiopia and also Kenya, but have a longer engagement with the Ugandan Government, and now accepting the harassment of opposition as a price for some form of stability.

While the other donor-funding is not questioning other than expressing some have cut funding over the $12 Million that was going to Northern Uganda Development Fund (NUDF) in the 2012, that went lost to through the Prime Minister Amama Mbabazi. Also the Anti-Gay Bill had their reactions from UK, Norway and Dutch who cut parts of their aid. So now it is the time again, as the oppression, election fraud and the man who want to be the Don and acts like the Don of Uganda. The Godfather of Uganda has spoken. He does not want to be inference. So since he does not wish to have interference the international donors and bilateral organizations should offer him a hand with that.

The International donors and bilateral organizations should certainly suspend their direct budget support to the Ugandan Government. As they don’t wish to have any interference and can handle it all on their own. The money should instead spend on the Multi-National Organizations working in Uganda, as the OCHA, UNICEF and WFP as they will submit and carry out quick resolved matters in Internal Displaced Camps and around the borders through their projects. Since that will not have any other government questioning their actions, then the other governments should not help to fund their actions. Simple rhetorical assessment that banish the 20 % power of the funds that Don Museveni has at his disposal and use; when outsiders are such a pain, then the pain should leave Don Museveni alone and not support him.

So the Donors and Bilateral organizations should cut their aid and give less power to Don Museveni and his NRM Mafia who spends and eats alone; while his government does not have money to build health care, roads, schools or the other necessities in the Ugandan Society. But not with Foreign tax-payers money, when they get used on the expensive cars, lavish lifestyle, foreign health care and private planes for the Godfather. There is time to take action as the gangster will act as Don and not as a Statesman. Henceforth, when a player does not want question, but accept your money and not accountable for them; and when the player squander the money and expect to get away with it. Then the Player should lose the ability to get the money from you. The Don Museveni have already had long enough time to deliver and used enough of donor-funds without showing progress. Time to cross out the donor-funding to direct budget support; then Don Museveni does not need to be questioned. As the international community will not have put a stake and being stakeholders for certain parts of the budget. But when they step away, then Don Museveni can be the kingpin and the gangster he want to be in military fatigue and do as he want in his playground, without opposition who should just stay home; and also without foreigners questioning him. Then he can rule alone with the capos, underbosses and then be grand Don Museveni. Peace.  

DNB Nor plan of setting up a Carlson Funds as a “Societe Anonyme” (S.A.) to initially save taxes and write of their subsidiary in Luxemburg; they might claim differently to save face, but the agreement with Luxemburg Authorities says otherwise!

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 2^nd 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.

Reference:

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)

Foss, Andres Bakke – ‘DNB i redegjørelse i 2014: DNB Luxembourg hjelper ikke kundene med å unndra skatt’ (08.04.2016) link: http://www.aftenposten.no/okonomi/DNB-i-redegjorelse-i-2014-DNB-Luxembourg-hjelper-ikke-kundene-med-a-unndra-skatt-8422413.html#xtor=RSS-3