My friend and now Task Force on Financial Integrity and Economic Development colleague Nick Mathiason also works for the Bureau of Investigative Journalism where he has exposed a new type of tax avoidance activity centred on the City of London today. As he wrote today in a story that also featured in the Observer:
Some of the city of London’s biggest banks are behind a huge tax avoidance trade ‘cheating’ European countries of hundreds of millions of euros a year in a development that sheds fresh light on David Cameron’s decision to wield Britain’s EU veto to protect the Square Mile.
A two-month study by the Bureau has uncovered a discreet $102bn market in European shares whose ‘central’ purpose is tax avoidance. The Bureau’s analysis suggests the European tax loss – mainly to France, Germany and Italy – is up to €595m a year. The scale of tax avoidance will fuel further anger within the EU towards the Square Mile, where the vast majority of the trade known as dividend arbitrage is conducted.
The number, like all such numbers, is an estimate. The point is it's happening. And London's arranging it. And UK banks are doing it. And David Cameron's defending it. As Nick notes:
Dividend arbitrage is complex. But at its heart, a bank or hedge fund lends equities in often high yielding French, German or Italian companies to another institution. The receiving institution then passes the equities through a network of low or no tax jurisdictions before returning the equities to the original owner using a subsidiary in another tax haven. In this way, banks can avoid the 15% average withholding tax levied on dividends in European countries.
For hedge funds based in the Cayman Islands or Bermuda, the trade is particularly useful in slashing tax bills.
There had, of course, to be a tax haven dimension. There always is in London. And a Swiss dimension too. As Nick again notes:
Credit Suisse, the giant Swiss financial services institution, is among a host of international banks and hedge funds involved. The Bureau has seen a Credit Suisse document that details how to implement dividend arbitrage strategies and has received confirmation from a senior derivative executive that the bank was an active participant. When asked whether Credit Suisse engaged in aggressive tax avoidance, the bank declined to comment. Among other banks said by City sources to be major dividend arbitrage players are Barclays Capital, Bank of America and Morgan Stanley. All declined to comment.