Off shore you can!
DR, it must be sufficient. Otherwise, HMRC selling off it's freehold to an offshore Company in Bermuda that reduced the quote on the deal by the amount of tax it saved and within the letter of the law would be a real problem.
For those who can't remember, it was a deal with a company called Mapeley. And here is what a Treasury Committee said of it at the time (2003):
“In February 2003 the Committee produced a report on the handling of the joint Inland Revenue and HM Customs and Excise STEPS PFI project. The project involved the transfer of some 600 Inland Revenue and Customs and Excise properties to part of the Mapeley Group, an offshore company registered in Bermuda, in return for an up front cash payment of £220 million, together with a further £150 million in the form of discounted service prices.”
It went further and said:
“The Committee accepted “that Mapeley was entitled to minimise its tax liabilities and the evidence that the avoidance of tax in this case was legal.”2 However, the Committee considered that “the Inland Revenue, responsible for implementing the Government’s policy of reducing tax avoidance, should of all departments have been alert to the difficulties of being party to a deal that transferred ownership of its properties to an offshore company.”
It added:
“The Inland Revenue and Customs and Excise maintained that procurement law
prevented them excluding bidders from using an offshore tax structure and that that had been confirmed by advice from leading Counsel. The Committee recommended that procurement guidance be reviewed to ensure that it contains comprehensive advice on this matter. The Committee also recommended that “further advice is sought and published so as to clarify whether it is possible to exclude bidders using an offshore tax haven in similar circumstances, and to restrict final beneficial ownership to companies registered in countries that have signed the agreement on Government Procurement. In particular, advice should be sought as to whether specifying this exclusion in the tender advertisement makes it lawful.”
So there you have it. Clear as Bermuda sand soiled by British beach dirt!
Originally posted by DonkeyRhubarb
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For those who can't remember, it was a deal with a company called Mapeley. And here is what a Treasury Committee said of it at the time (2003):
“In February 2003 the Committee produced a report on the handling of the joint Inland Revenue and HM Customs and Excise STEPS PFI project. The project involved the transfer of some 600 Inland Revenue and Customs and Excise properties to part of the Mapeley Group, an offshore company registered in Bermuda, in return for an up front cash payment of £220 million, together with a further £150 million in the form of discounted service prices.”
It went further and said:
“The Committee accepted “that Mapeley was entitled to minimise its tax liabilities and the evidence that the avoidance of tax in this case was legal.”2 However, the Committee considered that “the Inland Revenue, responsible for implementing the Government’s policy of reducing tax avoidance, should of all departments have been alert to the difficulties of being party to a deal that transferred ownership of its properties to an offshore company.”
It added:
“The Inland Revenue and Customs and Excise maintained that procurement law
prevented them excluding bidders from using an offshore tax structure and that that had been confirmed by advice from leading Counsel. The Committee recommended that procurement guidance be reviewed to ensure that it contains comprehensive advice on this matter. The Committee also recommended that “further advice is sought and published so as to clarify whether it is possible to exclude bidders using an offshore tax haven in similar circumstances, and to restrict final beneficial ownership to companies registered in countries that have signed the agreement on Government Procurement. In particular, advice should be sought as to whether specifying this exclusion in the tender advertisement makes it lawful.”
So there you have it. Clear as Bermuda sand soiled by British beach dirt!
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