[Closed] Paradise Papers

Why wouldn’t you use a Cayman etc vehicle to run investments, its [b]perfectly legitmate as the BBC quite rightiy say. Tax is paid when money is repatriated to the UK or elsewhere.

Anyone here read the Guardian or support Everton ... tax efficient ownership structures

Blame the idiot politicians that allow loopholes like this to exist. It's not illegal, can't fault someone for trying to legally minimise their tax bill.

So why would you use a company based in the Caymans, over one on the UK?

@kimbers I think so the same capital gain doesn't get taxed twice. For e.g. the fund holds the investments, you hold units/shares in the fund. If the fund itself (a corporate entity) was in the UK then the gains would be taxed. You as the investor would also be taxed when you sold your units/shares (assuming there was a gain).

I may be wrong. It doesn't feel like even a moral issue - the person owning the units still gets taxed on the capital gains? It's a bit like the furore over David Cameron's dad - total non-issue.

That's not to say there aren't nefarious things going on with offshore funds, just that I'm not sure the Queen's arrangement is one of them.

So your argument is they do it and they dont actually save any tax doing it 😯 that is the only point to them to reduce your tax burden. I would have thought we would all agree on that and only debate whether it was good or bad or whether we would all do it or some such

because you are incredibly wealthy , perhaps a millionaire or a billionaire and you want to make sure you pay less tax as a percentage of your massive income than a cleaner.

Its perfectly legal but its immoral and done by selfish ****s and defended by the same

Ashcroft looked incredibly silly being followed to the toilets by the reporter. It's not the use of the vehicles to avoid tax that's being exposed it's the failure to abide but the legal requirements when doing so, but I suspect yon knew that Jamby

@kimbers I think so the same capital gain doesn't get taxed twice.For e.g. the fund holds the investments, you hold units/shares in the fund. If the fund itself (a corporate entity) was in the UK then the gains would be taxed. You as the investor would also be taxed when you sold your units/shares (assuming there was a gain).

But surely loads of things are taxed twice eg business rates, corp tax, salaries.

Why do people object to money going to the Exchequer, particularly when they already have so much?

Didn't Ashcroft say he'd dropped his non-dom status,
Hague told us he'd be paying millions when he became a lord.... It was a lie

But surely loads of things are taxed twice eg business rates, corp tax, salaries.

because you are incredibly wealthy , perhaps a millionaire or a billionaire and you want to make sure you pay less tax as a percentage of your massive income than a cleaner.

We pay our cleaner in cash :-/

are all her customers this dishonest 😉

Why do people object to money going to the Exchequer, particularly when they already have so much?

They have so much partly because.....

Oh never mind.

Blame the idiot politicians that allow loopholes like this to exist.

So why would you use a company based in the Caymans, over one on the UK?

Lots of reasons though with a fund, you would be looking at a unit trust setup in the UK rather than a company. The rules applying to onshore funds often take a bit of time to catch up with what is happening in the world of finance so perfectly sensible investment strategies using derivatives used to fall foul of the rules so instead you use a tax haven. A classic example, albeit in the corporate rather fund arena, of this was companies who borrowed in a foreign currency but swapped the proceeds in sterling so net net they had borrowed in sterling. However if they did this onshore they were made a taxable gain or loss on the swap, but the equal and opposite loss or gain on the loan was untaxed so on a post tax basis you weren't hedged. Companies set up offshore borrowing vehicles who did both transactions and then lent the funds in Sterling to the UK company, problem solved. The rules were changed eventually but it took years to happen.

I have no idea what that means!

I have no idea what that means!

But neither would a lot of journalists but that doesn't stop them creating a fuss, my experience is that offshore centres whilst used for tax avoidance, and the bad ones tax evasion, they are just as often used for cost saving, flexibility, speed, providing a neutral environment etc etc.

What he said.

my experience is that offshore centres whilst used for tax avoidance, and the bad ones tax evasion, they are just as often used for cost saving, flexibility, speed, providing a neutral environment etc etc.

So you reckon half the estimated >$10tn held offshore is because of tax evasion/avoidance.

Sounds worthy of making a fuss to me

DM on top form there cubist!

So you reckon half the estimated >$10tn held offshore is because of tax evasion/avoidance.

No, I think the vast majority will be in funds looking for tax neutrality because they have tax exempt investors, what is the source for that number?

DM on top form there cubist!

What he fails to mention is that Gary Barlow's scheme didn't work, which is the reason it became known about, so he may have tried to avoid tax but he failed like the vast majority of recent schemes.

$10tn from the Boston consulting group via BBC

http://www.bbc.co.uk/news/uk-41876942

"I'm so honest that I funnel all my money through 18 shell companies in the Caymans, then distribute that between 17 trusts that are bonded to offshore investments that payout in tax neutral dividends to my office in Luxembourg, where I've never been."

Thank you, here is a [url= https://www.bcgperspectives.com/content/articles/financial_institutions_growth_trends_offshore_wealth_global_wealth_2013/ ]link [/url]to a BCG article on the subject and you will see that this covers alot of financial centres rather than just the classic tax havens - it is very much about the fund management industry hence the UK appears as a destination for offshore funds.

https://www.theguardian.com/business/2016/sep/22/amber-rudd-facing-calls-to-clarify-involvement-in-tax-havens

are all her customers this dishonest

Guilty as charged m'lud. I assume you have never asked "how much for cash mate?".

Bottom line is that most people will try and get away with paying tax if they can.

From the Amber Rudd thread over >>>>>

Her involvement in business through her father's dodgy dealings have been extensively covered by Private Eye and she has declined to answer all questions.
The attached article summarises but doesn't carry the details uncovered by the Eye.
https://www.theguardian.com/politics/2016/oct/05/revealed-amber-rudds-father-was-involved-in-business-she-ran-despite-being-declared-unfit

I have also commented in other posts.
Claims about her questionable financial dealings are nothing new.

Looks like a Money Tree to me. Shake it and build some council houses.

funds looking for tax neutrality because they have tax exempt investors,

How does one become a tax exempt Investor?

Coz I get taxed on the measly interest in get from my piss poor savings account !

How does one become a tax exempt Investor?

Turn yourself into a Pension fund or charity

Queen has money invested in a country where she is head of state shocker. I don't get it, what am I supposed to be offended about?

Nice to see Margaret Hodge on the telly pontificating about how awful it is for the Queen to have these offshore investments. Of course, this won't be the same Margaret Hodge whose family trust was, for years, held offshore.*

See also: The Guardian and the undoubted commercial advantages the Scott Trust's offshore activities offer.

*Says she never personally benefited while it was offshore blah blah, although it could be argued that the years her family trust sat offshore it was accruing value which will no doubt benefit her and her children at some point.

Queen has money invested in a country where she is head of state shocker. I don't get it, what am I supposed to be offended about?

You haven't read the details then. She didn't invest in a shopping centre in the Cayman Islands. The money was funnelled via there to buy various UK businesses.

Nothing illegal but one hoped for a 'higher standard' to be applied (and for it to be illegal).

Love this;

Leku - Member
Nothing illegal but one hoped for a 'higher standard' to be applied (and for it to be illegal).

For it to be illegal is down to "her government", which she has no say in.

quote, Lord Clyde, blah blah, paraphrase, don't let the revenue nick your money that is rightfully yours where legally possible.

If you won big on the lottery, almost all of us would be straight down to a financial adviser and getting it invested offshore, else the interest from it would be massively hit, plus there are huge tax hits on inheritance and gifting. Inheritance tax in particular being an issue for syndicates if any of them die.

I didn't see the programme yet. Any idea roughly how much the Queen has robbed the state of by hiding some of her affairs abroad? it is so much money to get upset about or is it just a little bit?

I'm more enjoying the fact that the Queen's dosh was reinvested in businesses selling booze and rip-off tellies on HP to the little people. I wonder how many other investments in the rather lucrative sub-prime marketplace the Duchy of Lancaster has?

You haven't read the details then. She didn't invest in a shopping centre in the Cayman Islands. The money was funnelled via there to buy various UK businesses.

Nothing illegal but one hoped for a 'higher standard' to be applied (and for it to be illegal).

I still don't get it. Put it in layman's terms for me since I'm not a financier or tax dodger... let's say I, at some point in the past, bought a house and a car and a fancy ride-on lawnmower on an island, and opened a bank account, coz, well, you know, I own the island and I like to go there a few weeks a year. Then I found out the lawnmower I bought was a rare example of an old John Deere that was now worth 50 times what I paid for it, so I decided to sell it and then put the money I made into a business on another island that I also own but is where I live most of the time. And the people of the island where I live most of the time want me to give them some money for selling my lawnmower and putting the proceeds into a business? Is that like what she's done?

Interesting to look back on the Panama Papers thread:

http://singletrackmag.com/forum/topic/jivehoney-and-tales-of-the-unexpected/page/26?replies=904#post-7691500

the wealthy minority running the [s]country[/s] world to the benefit of themselves.

Let's imagine for a moment that all of the following problems can be linked to offshore tax havens, most of which come under the jurisdiction of the British Crown

Illicit Arms Trafficking
ISIS/Daesh
The Refugee Crisis
Human Trafficking and organized Child Abuse
Environmental Catastrophe
Climate Change and the melting of the Polar Ice Caps

Worth having a go at making a positive change?

There's even mention of BAE Systems and HSBC in there...

Further sources have revealed that Gerald Carroll’s Farnborough Aerospace Aerospace Centre in Hampshire England was “targeted” by BAE Systems and HSBC International within the framework of a systematic break-up embezzlement operation

Now surely this can't have anything to do with the Queen?

It may be a while off but a social uprising is coming. Wealth disparity has hit breaking point and when its a (supposed) beacon of hope and trust that is found to take the piss (The Monarchy) it will only accelerate the process

All imo of course but the whole things unsustainable

Edit i'll try to dig it out but John Paul Tudor Jones gave a talk on how it will happen

Is that like what she's done?

no.

"I fancy buying the off-license on the (UK) High Street".
"Excellent idea. Cash or cheque?"
"Cheque, but first I'll post the cheque to the Cayman Islands so that the little people can't se what I'm doing."
"Wonderful. I hear it's lovely this time of year."
"I wouldn't know, but my cash has a nice sun-tan."

[quote=jekkyl ]I didn't see the programme yet. Any idea roughly how much the Queen has robbed the state of by hiding some of her affairs abroad? it is so much money to get upset about or is it just a little bit?

the Queen is exempt from tax, so none.

I see Trumps Commerce Secretary has been caught up in this 🙂 more Russian links.

the Queen is exempt from tax, so none.

Incorrect. She was exempt from tax but is no longer.

Edit: seems it's voluntary, but she has paid tax since 1993.

the Queen is exempt from tax, so none.

hmm something doesn't stack up as if she is exempt from all tax why invest it offshore at all?
from here: https://en.wikipedia.org/wiki/Finances_of_the_British_royal_family#Taxation

Crown bodies such as The Duchy of Lancaster are not subject to legislation concerning income tax, capital gains tax or inheritance tax. Furthermore, the Sovereign has no legal liability to pay such taxes. The Duchy of Cornwall has a Crown exemption and the Prince of Wales is not legally liable to pay income tax on Duchy revenues.

so it appears you're right, she is not legally liable for any tax, but..

The Queen and The Prince of Wales make voluntary payments to the HM Revenue and Customs in lieu of tax to compensate for their tax exemption. The details of the payments are private. The Queen voluntarily pays a sum equivalent to income tax on her private income

The question then remains, if the duchy is not legally liable for any tax why invest offshore? better interest rates? or what....?

If you are going to set up a globally focused business / asset management platform you do so in a tax efficient jurisdiction which can include so called “tax havens” (Luxembourg and Ireland qualify too). You do this as tax rates vary so widely accross the world and an investor in say Singapore where tax on interest and capital gains are ZERO it makes no sense for it to be put in a high tax location. Tax is paid when the money is repatriated to the country of residence. This is just the same as a pension where tax is paid when pension is drawn.

@Jekyl any investor the Queen included will pay tax when any income / profits are taken. The Queen voluntarily offered to pay tax some years ago, previously she did not have to. EU employees inc those at EIB in London pay something like a 10% tax rate

@jekyl as I tried to explain above they invest “offshore”as thats where the products are setup as they target a global client base

no.

"I fancy buying the off-license on the (UK) High Street".
"Excellent idea. Cash or cheque?"
"Cheque, but first I'll post the cheque to the Cayman Islands so that the little people can't se what I'm doing."
"Wonderful. I hear it's lovely this time of year."
"I wouldn't know, but my cash has a nice sun-tan."

ok, got that. So why is that a problem? And why should I be offended by the fact I am a little person who didn't get to observe the transaction any more than I don't get to observe, say, yours?

The question then remains, if the duchy is not legally liable for any tax why invest offshore? better interest rates? or what....?

It is how the Collectve Investment Scheme that invested some of her money is set up. The vast majority of Private Equity Funds are set up like this, so if you want to invest in the asset class, you are going to be doing it through an offshore fund. Why are they set up like this? It is the simplest and cheapest way of ensuring the "fund wrapper" doesn't create additional tax charges for a wide variety of potential investors. It is probably worth pointing out that the vehicles involved were LLPs. These are transparent entities for UK tax purposes so the Investor is regarded as entering into the transactions entered into by them directly, in proportion to their share of the income.

The term 'Tax Haven', is immediately suggestive of tax avoidance.
And historically huge sums have been avoided in them. Surely its right to be suspicious of this if there are onshore options that the Queen could invest in without damaging her reputation.

The term transparent also makes little sense , since we only learned of her Maj using offshore banking to invest in a company that charges the hardest up 70% APR to buy a telly, sofa or washing machine, have only come to light thanks to this leak, even the Queen herself apparently unaware.

Also have Tory & Brexit donor Ashcroft who had apparently renounced non-dom status, this leak shows he hasn't

And historically huge sums have been avoided, surely is right to be suspicious of this when surely there are non offshore options, that the Queen could invest in without damaging her reputation.

The wealth management firm my wife works for does not offshore at all, precisely because they do not want to get caught up in these kinds of leaks. They have a lot of clients who do not like political risk or social exposure.

They're doing pretty well for themselves.

are all her customers this dishonest

The most shocking thing on this thread is that Junky assumes a cleaner to be female. 😯

Usually I'm a bit 'meh' when it comes to tax avoidence/evasion threads, not because I agree with it but because its no surprise that some of the richest people in the country are also some of the greediest

But nothing quite boils my piss like the queen doing this, whilst expecting her loyal subjects, the tax payers, to forkout around 350 million quid to renovate her home

Sooner we get rid of the monarchy the better..french had the right idea

Surely its right to be suspicious of this if there are onshore options that the Queen could invest in without damaging her reputation.

Very few onshore options for Private Equity (same for Hedge Funds). The problem is journalists just don't understand how this stuff works.

The term transparent also makes little sense

It is a tax technical term in the context I used it because you "look through" the entity and tax the underlying transactions. Hence no tax advantages.

Remember all the fuss when the Panama papers were leaked?

Does anybody know what, if anything, happened as a result of those?

Perhaps the Crown shouldn't be investing with private equity firms and hedge funds in the first place, there are plenty of less politically risky options to choose from.

The problem is journalists just don't understand how this stuff works.

I'd be careful with such general assmptions - there are plenty of investigatove journalists who understand pretty well how this stuff works.

How the jpournalists then present it back to the reading/watching public is a different matter - none of it is actually that complex though it can be complicated in how convoluted it is. But if you want your readership/watchers to remai engaged, make it easy to understand in bite sized chnks.

I don't see anything that suggests outright illegality (Ashcroft may be the obvious exception) but the principle is about morality and inequality.

When, 10 years after the financial crisis that nearly collapsed the global economy and ushered in austerity across the western world, people have seen the gap between rich and poor grow wider and wealth concentrated in the key financial centres, it's hard to ignore that the morality of how rich people avoid paying their taxes is at the top of the list.

http://www.bbc.co.uk/news/uk-41886608

on the plus side, this might lead to an improvemt in the nations telly

Perhaps the Crown shouldn't be investing with private equity firms and hedge funds in the first place, there are plenty of less politically risky options to choose from.

Is it the principle of private equity or of hedging that you find unacceptable?

@mefty - I thank you for your indefatigability but there is really no point trying to explain this anymore. Either people will invest the time thinking about what is really wrong (i.e. it's not the Queen's offshore funds), or they won't and we'll end up with the idiots running the asylum and universally detrimental outcomes (cf Brexit).

Neither really, but it is utterly false to state or imply that they could not have invested in a way that didn't expose them like this.

bainbrge - Member
Is it the principle of private equity or of hedging that you find unacceptable?

and yet here you are you are missrepresenting what Tom is saying

hes saying that hedge funds & private equity firms are unpopular & 'politically risky'

not that he finds them unacceptable

It turns out one of the mastermind tax dodge accountant's offices is only 5 miles from my office. It'd be handy to not pay any tax or NI in the run up to christmas, it would really take the pressure off and save Mrs P from worrying about whether we can afford to buy the kids any presents.

I'm sure its the same for actors/business types. It must be a real worry, whether they'll get through the next few months with just ALL THE MONEY I WILL EVER EARN.

I’ve said a few times people in the media and sports are some of the biggest tax swervers. It would be quite illuminative for people to see the tax arrangements of Russell Brand, Graham Norton or Gary Linekar for example

http://www.bbc.co.uk/news/uk-41886608

We just saw Jose M pay €3m in tax in Spain after being taken to court (Messi paid slightly more) as image rights payments where sent offshore.

What the likes of Jamba & Mefty rather conveniently overlook is the detail that the vast majority of these offshore transactions are indeed structured with the direct intent to reduce the final tax bill to the user, the original investor. That is a significant part of maximising the investment yield. There will be a point in the investment chain somewhere that breaks the connection between yield and ownership, so that in the simplest of cases, a 'loan' is made back to the investor or a gain is realised in a non-taxable location. This deliberate and frequently quite artificial action is far beyond dubious, on any decent person's moral compass.

Quite simply, as a proportion of income, the richest face the smallest tax bills and these offshore investment platforms play a major part in helping that happen.
If anyone thinks that these investment vehicles are a good idea, they should go and spend a day volunteering at a food bank. Then come back and tell us if their views on tax avoidance have changed any.

Alternatively: Off with their heads.

Referring back to the first page - presumably Gary Barlow will be asking for the large fee he paid to the tax consultant back, then? No?

Even if it is all legit, it is not a service that is available to the normal man in the street. You have to be in the wealthy club to be able to afford the advice fees, so that's unfair to begin with.

Secondly, if you are willing to incur eye-watering fees for tax consultancy and still deem it to be financially worthwhile, it must be a way of paying at least less tax than the cost of those fees - otherwise they wouldn't do it(!)

jambalaya - Member
I’ve said a few times people in the media and sports are some of the biggest tax swervers. It would be quite illuminative for people to see the tax arrangements of Russell Brand, Graham Norton or Gary Linekar for example

Well they're not swerving as much tax as Amazon, Starbucks, Vodafone et al

Thanks Kimbers, but it was just a question.

If Tom has a pension then there is decent chance some of his funds are invested in private equity, offshore vehicles, or 'hedge funds'. That's because there is nothing in principle wrong with any of these things.

Not trying to have a dig, but there is a fundamental lack of understanding on display here and mostly everywhere else that is obscuring the real issues. The Guardian/ICIJ are guilty of obscuring the issue through releasing salacious details about famous people that imply wrongdoing, but as they seem to say in every article 'no evidence of anything illegal'.

I'm quite ready to believe that artificial tax structures like the one Jimmy Carr invested in are illegal (and given changes in tax legislation increasingly difficult to achieve given everything has to be pre-notified to HMRC). I'm also sure that there is loads of illegal extraction of assets from various dodgy jurisdictions by criminal entities - that is the real story for me. However offshore funds per se are not the issue at all, especially not in the context of Her Maj and her investment decisions!

- any UK tax payer is liable to pay tax upon profits earned by an offshore fund (so doesn't matter if the fund is in Cayman or Timbuktu)
- you could of course try and not disclose your gain, but that would be illegal and increasingly likely to be picked up by HMRC.
- If the offshore fund is in a zero tax jurisdiction then there is zero tax taken at source.
- Hence there is no tax loss to the exchequer by investing in an offshore fund in this example - the tax is paid in the UK according to the gain.
- if the offshore fund was in a country that actually taxed the fund at source, then the UK exchequer would actually be worse off, because in most cases you don't get taxed twice, and there would be a tax refund from the UK exchequer equal to the amount paid at source.
- there are many good reasons to setup your fund in a tax neutral jurisdiction, especially if you have international investors, as detailed above by Mefty (and I mean good as in good that satisfies both legal and moral considerations).

Thanks Kimbers, but it was just a question.

If Tom has a pension then there is decent chance some of his funds are invested in private equity, offshore vehicles, or 'hedge funds'. That's because there is nothing in principle wrong with any of these things.

Not really, if the crown could use plausible deniability eg... the excuse "oh that wasn't us - that was the pension manager we use" - that would be the case.

The thing that you miss is that whilst in many cases there is nothing wrong with investing in private equity, it attracts far far too much attention from the press and the public - for that reason, I am quite surprised that the crown got caught up in all of this - with their history of watching the French revolution unfold over the channel etc.

Yes, I don't have the best understanding in the world in regards to finance, but I do know my wife works for a firm that goes out of its way to make sure that clients are not tarnished like this.

@kilo Agreed

How's about anyone who registers as "non dom" for tax purposes also give up their British citizenship at the same time, seems fair enough to me. One area where the Americans do seem to have got it right in my book.

Dickyboy - Member
How's about anyone who registers as "non dom" for tax purposes also give up their British citizenship at the same time, seems fair enough to me. O

good idea, lets ask Lord Ashcroft

hes just here, oh hang on....

[img] [/img]

Best give him citizenship of the toilet?

How's about anyone who registers as "non dom" for tax purposes also give up their British citizenship at the same time, seems fair enough to me.

Non Dom should be abolished full stop. Greatest number of non dom's where registered during the Blair/Brown era FWIW

@Kimbers what you are doing (and it's not just you it's just you posted above) is trying to turn this into some sort of political / class war bollix when sports people and actors/performers are some of the very biggest tax dodgers.

What really makes my blood boil is when the BBC supports tax avoidance on performers incomes. That's licence fee tax payers money.

There is a material difference between investment products which look to crystallise taxable gains at maturity and people using offshore havens as a way of avoiding income tax.

The BBC should hire people on PAYE only, this includes any production companies. All staff must receive all income via PAYE. If they cannot comply they cannot be hired.

jambalaya - Member
How's about anyone who registers as "non dom" for tax purposes also give up their British citizenship at the same time, seems fair enough to me.

Non Dom should be abolished full stop. Greatest number of non dom's where registered during the Blair/Brown era FWIW

@Kimbers what you are doing (and it's not just you it's just you posted above) is trying to turn this into some sort of political / class war bollix when sports people and actors/performers are some of the very biggest tax dodgers.

What really makes my blood boil is when the BBC supports tax avoidance on performers incomes. That's licence fee tax payers money.

There is a material difference between investment products which look to crystallise taxable gains at maturity and people using offshore havens as a way of avoiding income tax.

The BBC should hire people on PAYE only, this includes any production companies. All staff must receive all income via PAYE. If they cannot comply they cannot be hired.

Y’know what?

I agree with you.

@Kimbers what you are doing (and it's not just you it's just you posted above) is trying to turn this into some sort of political / class war bollix when sports people and actors/performers are some of the very biggest tax dodgers.

really? I posted a link to the BBC TV stars tax dodging on the last page

but you keep telling me Im only out to slag off the tax dodging Tory/Brexit donors if it makes you feel better

What really makes my blood boil is when the BBC supports tax avoidance on performers incomes. That's licence fee tax payers money.

[img] [/img]

The BBC should hire people on PAYE only, this includes any production companies. All staff must receive all income via PAYE. If they cannot comply they cannot be hired.

isnt the problem that the BBC doesnt make the shows, it buys them in from production companies? would it be legal to enforce that kind of restriction, sounds like a good idea, plenty of direct government contractors eg ATOS & G4S go to great liengths including offshore tricks to avoid/evade tax

At last something to laugh about "Mrs Brown's Boys" hope it truly feks up their public image & they get dropped never to grace our screens again.

I agree with that!

God awful programme.

Kimbers what you are doing (and it's not just you it's just you posted above) is trying to turn this into some sort of political / class war

And your issue with that is?

Also, that is rich coming from a "**** the elites" Trump supporter.

Non Dom should be abolished full stop. Greatest number of non dom's where registered during the Blair/Brown era FWIW

100% agree on both counts.

I've just written to my MP to demand that we prevent non-domiciled individuals from making contributions to political parties and to ask for firm commitments to dealing with tax evasion. However he has his er, hands full right now fighting some allegations that he couldn't keep them in his pockets.

you could of course try and not disclose your gain, but that would be illegal and increasingly likely to be picked up by HMRC

As long as the HMRC found out, which us course is made more difficult by the fact that one of the more obvious benefits of off shore is the lack of public disclosure. Sure, they'll say they comply with all enquiries... As long as the tax authorities know what to ask.