They reveal how Apple sidestepped a 2013 crackdown on its controversial Irish tax practices by actively shopping around for a tax haven.

It then moved the firm holding most of its untaxed offshore cash, now $252bn, to the Channel Island of Jersey.

Apple said the new structure had not lowered its taxes.

It said it remained the world’s largest taxpayer, paying about $35bn (£26bn) in corporation tax over the past three years, that it had followed the law and its changes “did not reduce our tax payments in any country”.

In a further statement the company stressed that no operations or investments had been moved from Ireland.

The Paradise Papers is the name for a huge leak of financial documents that is throwing light on the world of offshore finance.

Up until 2014, the tech company had been exploiting a loophole in tax laws in the US and the Republic of Ireland known as the “double Irish”.

This allowed Apple to funnel all its sales outside of the Americas – currently about 55% of its revenue – through Irish subsidiaries that were effectively stateless for taxation purposes, and so incurred hardly any tax.

Instead of paying Irish corporation tax of 12.5%, or the US rate of 35%, Apple’s avoidance structure helped it reduce its tax rate on profits outside of the US to the extent that its foreign tax payments rarely amounted to more than 5% of its foreign profits, and in some years dipped below 2%.

The European Commission calculated the rate of tax for one of Apple’s Irish companies for one year had been just 0.005%.

Apple came under pressure in 2013 in the US Senate, when CEO Tim Cook was forced to defend its tax system.

Angry that the US was missing out on a huge amount of tax, then-Senator Carl Levin told him: “You shifted that golden goose to Ireland. You shifted it to three companies that do not pay taxes in Ireland. These are the crown jewels of Apple Inc. Folks, it’s not right.”

Mr Cook responded defiantly: “We pay all the taxes we owe, every single dollar. We do not depend on tax gimmicks… We do not stash money on some Caribbean island.”

Apple’s questionnaire

After the EU announced in 2013 that it was investigating Apple’s Irish arrangement, the Irish government decided that firms incorporated there could no longer be stateless for tax purposes.

In order to keep its tax rates low, Apple needed to find an offshore financial centre that would serve as the tax residency for its Irish subsidiaries.

In March 2014, Apple’s legal advisers sent a questionnaire to Appleby, a leading offshore finance law firm and source of much of the Paradise Papers leak.

It asked what benefits different offshore jurisdictions – the British Virgin Islands, Bermuda, the Cayman Islands, Mauritius, the Isle of Man, Jersey and Guernsey – could offer Apple.

The document asked key questions such as was it possible to “obtain an official assurance of tax exemption” and could it be confirmed that an Irish company might “conduct management activities… without being subject to taxation in your jurisdiction”.

They also asked whether a change of government was likely, what information would be visible to the public and how easy it would be to exit the jurisdiction.

Source document: Apple questionnaire (extract)

Leaked emails also make it clear that Apple wanted to keep the move secret.

One email sent between senior partners at Appleby says: “For those of you who are not aware, Apple [officials] are extremely sensitive concerning publicity. They also expect the work that is being done for them only to be discussed amongst personnel who need to know.”

Apple chose Jersey, a UK Crown dependency that makes its own tax laws and which has a 0% corporate tax rate for foreign companies.

Paradise Papers documents show Apple’s two key Irish subsidiaries, Apple Operations International (AOI), believed to hold most of Apple’s massive $252bn overseas cash hoard, and Apple Sales International (ASI), were managed from Appleby’s office in Jersey from the start of 2015 until early 2016.

This would have enabled Apple to continue avoiding billions in tax around the world.

Apple’s 2017 accounts showed they made $44.7bn outside the US and paid just $1.65bn in taxes to foreign governments, a rate of around 3.7%. That is less than a sixth of the average rate of corporation tax in the world.

Apple and Ireland vs the EU

In August 2016, after a three-year investigation, the European Commission finds that Ireland gave an illegal tax benefit to Apple.

The EC says Apple must repay Ireland taxes for the period within its remit of investigation, 2003-2013, a total of €13bn (£11.6bn) plus interest of €1bn.

Ireland and Apple launch an appeal.

Apple’s Tim Cook calls the EC ruling “total political crap”, with “no reason for it in fact or in law”. Ireland says the EU is encroaching on sovereign taxation. It fears multinationals will go elsewhere.

Ireland agrees to collect the €13bn, to be held in a managed escrow account pending the appeal verdict.

In October 2017, the EU says it will take Ireland to court as it has not yet collected the money. Ireland says it is complicated and it needs time.

Massive GDP spike

When the “double-Irish” loophole was shut down, Ireland also created new tax regulations that companies like Apple could take advantage of.

One of the companies that Apple moved to Jersey, ASI, had rights to some of Apple Inc’s hugely valuable intellectual property.

If ASI sold the intellectual property back to an Irish company, the Irish company would be able to offset the enormous cost against any future profits. And since the IP holder, ASI, was registered in Jersey, the profits of the sale would not be taxed.

It appears Apple has done just that. There was an extraordinary 26% spike in Ireland’s GDP in 2015 which media reports put down to intellectual property assets moving into Ireland. Intangible assets rose a massive €250bn in Ireland that year.

Ireland’s department of finance denied that the new regulations had been brought in to benefit multinationals.

It said Ireland was “not unique in allowing companies to claim capital allowances on intangible assets” and had followed “the international norm”.

Apple declined to answer questions about its two subsidiaries moving their tax residency to Jersey.

It also declined to comment when asked whether one of those companies had helped create a huge tax write-off by selling intellectual property.

Apple said: “When Ireland changed its tax laws in 2015, we complied by changing the residency of our Irish subsidiaries and we informed Ireland, the European Commission and the United States.

“The changes we made did not reduce our tax payments in any country. In fact, our payments to Ireland increased significantly and over the last three years we’ve paid $1.5bn in tax there.”

The papers are a huge batch of leaked documents mostly from offshore law firm Appleby, along with corporate registries in 19 tax jurisdictions, which reveal the financial dealings of politicians, celebrities, corporate giants and business leaders.

The 13.4 million records were passed to German newspaper Sueddeutsche Zeitung and then shared with the International Consortium of Investigative Journalists (ICIJ). Panorama has led research for the BBC as part of a global investigation involving nearly 100 other media organisations, including the Guardian, in 67 countries. The BBC does not know the identity of the source.

Paradise Papers: Full coverage; follow reaction on Twitter using #ParadisePapers; in the BBC News app, follow the tag “Paradise Papers”

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Source: BBC

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According to the leak dubbed “Paradise Papers” and put together by International Consortium of Investigative Journalists (ICIJ), Ibrahim Mahama, had planned to open two different accounts in 2013 with international offshore law firm Appleby, but ended up opening just one.

[contextly_sidebar id=”gPChYovSubmzpYRXvJwaqX7oTKEsnn0v”]The report stated that, Ibrahim Mahama, Chief Executive Officer of Engineers and Planners, opened the account in the name of Red Sky Aviation Limited which has a $7 million Bombadier Challenger jet.

“In 2013, representatives of Mahama and his contracting company Engineers and Planners Company Limited contacted Appleby about creating two offshore companies in the Isle of Man but ended up creating only one. That company, Red Sky Aviation Limited, was used to hold a $7 million Bombardier Challenger jet.”

According to the Paradise Papers, Ibrahim Mahama’s companies were ranked by Appleby as “high risk” companies because of the owner’s relationship with former Ghanaian leader, John Mahama.

“The second company was intended for “consulting services in the oil and gas mining infrastructure development, and real estate sectors of the Ghanaian economy.”

Appleby ranked Mahama and his companies as a high risk due to his relationship to the then-president, and allegations in Ghanaian media that government funds were being used to repay the company’s multi-million-dollar bank loan.”

ICIJ in the report however noted that, when Ibrahim Mahama’s company was contacted on the issue, they “denied any wrongdoing.”

“A representative of Engineers & Planners Company Limited declined to respond to specific questions and told ICIJ that there was nothing illegal in the use of offshore companies,” the report added.

Paradise Papers: Tax haven secrets of ultra-rich exposed

The huge new leak of financial documents has revealed how the powerful and ultra-wealthy, including the Queen of England’s private estate, secretly invest vast amounts of cash in offshore tax havens.

America’s President, Donald Trump’s commerce secretary, is shown to have a stake in a firm dealing with Russians sanctioned by the US.

The leak, dubbed the Paradise Papers, contains 13.4m documents, mostly from one leading firm in offshore finance. BBC Panorama is part of nearly 100 media groups investigating the papers.

As with last year’s Panama Papers leak, the documents were obtained by the German newspaper Süddeutsche Zeitung, which called in the International Consortium of Investigative Journalists (ICIJ) to oversee the investigation.

EOCO chases Ibrahim Mahama

Ibrahim Mahama has been hot this year, 2017, after he was ordered in April to pay about GHc12 million by the Economic and Organised Crime Office (EOCO) for duty on goods he cleared with dud cheques in 2015 plus interest.

Panama papers

In 2016, a similar report was released which captured thousands of wealthy people who have hidden their treasures in offshore accounts.

The report named the sons ex-President John Agyekum Kufuor and UN Secretary General Kofi Annan, as some Ghanaians who operated such accounts.

They’ve done no wrong

A private legal practitioner, Ace Ankomah, at the time explained that, such persons cited in the operation of foreign accounts, have committed no offence.

“The existence of a tax haven is in itself not wrong” but “it is believed that such accounts are used for all kinds of nefarious activities; money laundering, tax avoidance among others,” he added.

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By: citifmonilne.com/Ghana

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Donald Trump’s commerce secretary is shown to have a stake in a firm dealing with Russians sanctioned by the US.

The leak, dubbed the Paradise Papers, contains 13.4m documents, mostly from one leading firm in offshore finance.

BBC Panorama is part of nearly 100 media groups investigating the papers.

As with last year’s Panama Papers leak, the documents were obtained by the German newspaper Süddeutsche Zeitung, which called in the International Consortium of Investigative Journalists (ICIJ) to oversee the investigation.

Sunday’s revelations form only a small part of a week of disclosures that will expose the tax and financial affairs of some of the hundreds of people and companies named in the data, some with strong UK connections.

Many of the stories focus on how politicians, multinationals, celebrities and high-net-worth individuals use complex structures of trusts, foundations and shell companies to protect their cash from tax officials or hide their dealings behind a veil of secrecy.

The vast majority of the transactions involve no legal wrongdoing.
Other key stories being released on Sunday are:

• A key aide of Canada’s PM has been linked to offshore schemes that may have cost the nation millions of dollars in taxes, threatening to embarrass Justin Trudeau, who has campaigned to shut tax havens
• Lord Ashcroft, a former Conservative party deputy chairman and a significant donor, may have ignored rules around how his offshore investments were managed. Other papers suggest he retained his non-dom status while in the House of Lords, despite reports he had become a permanent tax resident in the UK
• How questions were raised about the funding of a major shareholding in Everton FC

The other media partners may be covering different stories affecting their regions.
How is the Queen involved?

The Paradise Papers show that about £10m ($13m) of the Queen’s private money was invested offshore.

It was put into funds in the Cayman Islands and Bermuda by the Duchy of Lancaster, which provides the Queen with an income and handles investments for her £500m private estate.

There is nothing illegal in the investments and no suggestion that the Queen is not paying tax, but questions may be asked about whether the monarch should be investing in offshore finance.

There were small investments in the rent-to-buy retailer BrightHouse, which has been accused of exploiting the poor, and the Threshers chain of off-licences, which later went bust owing £17.5m in tax and costing almost 6,000 people their jobs.

The Duchy said it was not involved in decisions made by funds and there is no suggestion the Queen had any knowledge of the specific investments made on her behalf.

The Duchy has in the past said it gives “ongoing consideration regarding any of its acts or omissions that could adversely impact the reputation” of the Queen, who it says takes “a keen interest” in the estate.

Embarrassment for Ross and Trump?
Wilbur Ross helped stave off bankruptcy for Donald Trump in the 1990s and was later appointed commerce secretary in Mr Trump’s administration.

The documents reveal Mr Ross has retained an interest in a shipping company which earns millions of dollars a year transporting oil and gas for a Russian energy firm whose shareholders include Vladimir Putin’s son-in-law and two men subject to US sanctions.

It will again raise questions about the Russian connections of Donald Trump’s team. His presidency has been dogged by allegations that Russians colluded to try to influence the outcome of last year’s US election. He has called the allegations “fake news”.

Where does the leak come from?
Most of the data comes from a company called Appleby, a Bermuda-based legal services provider at the top end of the offshore industry, helping clients set up in overseas jurisdictions with low or zero tax rates.

Its documents, and others mainly from corporate registries in Caribbean jurisdictions, were obtained by Süddeutsche Zeitung. It has not revealed the source.

The media partners say the investigation is in the public interest because data leaks from the world of offshore have repeatedly exposed wrongdoing.

In response to the leaks, Appleby said it was “satisfied that there is no evidence of any wrongdoing, either on the part of ourselves or our clients”, adding: “We do not tolerate illegal behaviour.”

What exactly is offshore finance?
Essentially it’s about a place outside of your own nation’s regulations to which companies or individuals can reroute money, assets or profits to take advantage of lower taxes.

These jurisdictions are known as tax havens to the layman, or the more stately offshore financial centres (OFCs) to the industry. They are generally stable, secretive and reliable, often small islands but not exclusively so, and can vary on how rigorously they carry out checks on wrongdoing.

The UK is a big player here, not simply because so many of its overseas territories and Crown dependencies are OFCs, but many of the lawyers, accountants and bankers working in the offshore industry are in the City of London.
It’s also about the mega-rich. Brooke Harrington, author of Capital Without Borders: Wealth Managers and the One Percent, says offshore finance is not for the 1% but the .001%. Assets of around $500,000 (£380,000) would just not meet the offshore fees the schemes would need, she says.

What is the effect on us and should we care?
Well, it is a lot of cash. The Boston Consulting Group says $10tn is held offshore. That’s about the equivalent of the gross domestic products of the UK, Japan and France – combined. It may also be a conservative estimate.

Critics of offshore say it is mainly about secrecy – which opens the door to wrongdoing – and inequality. They also say the action of governments to curb it has often been slow and ineffective.

Brooke Harrington says if the rich are avoiding tax, the poor pick up the bill: “There’s a minimal amount the governments need to function and they recoup what they lose from the rich and from corporations by taking it out of our hides.”

Meg Hillier, UK Labour MP and chair of the Public Accounts Committee, told Panorama: “We need to see what’s going offshore; if offshore was not secret then some of this stuff just couldn’t happen… we need transparency and we need sunlight shone on this.”

What is the defence of offshore?
The offshore financial centres say that if they did not exist, there would be no constraint on taxes governments might levy. They say they do not sit on hoards of cash, but act as agents that help pump money around the globe.

Bob Richards, who was Bermuda’s finance minister when Panorama interviewed him for its programme, said it was not up to him to collect other nations’ taxes and that they should sort themselves out.

Both he and Howard Quayle, the chief minister for the Isle of Man, who was also interviewed for Panorama and whose Crown dependency plays a big part in the leaks, denied their jurisdictions could even be considered tax havens as they were well regulated and fully conformed to international financial reporting rules.

Appleby itself has in the past said OFCs “protect people victimised by crime, corruption, or persecution by shielding them from venal governments”.

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Source: BBC

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Capital One discovered that women take nearly 20 per cent longer than men to recover from the breakdown of a long-term relationship and that on average, we need one month of healing time for every year spent together to fully get over a breakup.

And even more great news: seven per cent of men would take less than a week to move on from the breakdown of a five-year relationship. (really, guys?).

To find out why and how to deal with it, psychologist Donna Dawson talks about how to actually, properly, finally get over your break-up and stop thing about your ex boyfriend for good

“We have to treat a breakup like a mini bereavement; this is the death of a relationship,” says Donna. “In some ways the steps to cope are exactly the same.”

‘What are these blimmin’ steps?’ we hear you cry! Well, here you are:

1. Make a list of why they sucked.

“Women are more likely to dwell on the happy memories and to see things through rose-tinted glasses. To stop this, remind yourself of all the things that really caused the breakup and all those problems you overlooked because you wanted to be in love.

“Pin it somewhere so you can see it every day.”

2. Get rid of the pictures.

“Ideally, throw out all of the cards he sent you, all the presents. If you can’t dare to do that, put them in a box and give it to someone you trust. They can stick it in the loft until you’re at a point where you are over the sentimental connection.”

3. Tell your friends to stop talking about them.

“If you need some time to grieve with your girls, set a time limit of a week or two. After that, ban them from talking about it.

“Over-analysing the breakup or hearing about how they’ve seen him with another girl won’t help anyone. Draw a line in the sand and just start moving on.”

4. Have a social media detox.

“Binning the ex-related goods applies to Facebook and Twitter, too. The last thing you need is a daily reminder of what they’re up to and who they’re with.

“You have to move on mentally as well as physically, and you can’t move on mentally unless the physical stuff happens first. Delete, delete, DELETE!”

5. Stop clinging on to ‘being friends’.

“Why would you want to be friends with somebody who has broken up with you? If they didn’t love you enough to date you, why would you want them as a friend? You don’t need him!

“There’s no such thing as being friends with an ex-lover. There is too much temptation to rehash old insecurities, question what went wrong and dwell on your shared experiences. Stop living in the past.”

6. Embrace the single life.

“If you move in circles with a lot of couples, stay away! Get yourself a hobby or hang out with your single friends and make some NEW memories. Do something different to start the new you.

“All those things that you didn’t feel you could do when you were with him – do them. Even if it’s just sitting in bed and making crumbs eating a whole packet of biscuits.”

7. The best revenge is indifference.

“Join a new class at the gym, change your hair or treat yourself to some new clothes, but do it for YOU. In their worst moments, your ex will want to think that you are weeping and wailing about them, so the best thing you can do is think, ‘I can make myself happy and actually I’m better off without you.'”

8. Step away from Tinder.

“It’s much easier to convince yourself you’re ready to meet someone new from the comfort of your own home and this will encourage you to jump into a rebound relationship. Which won’t help in the long-term.

“The other problem with online dating is that it’s much easier to project a set criteria of what you’re looking for (and compare them to an ex) than if you develop chemistry with someone spontaneously when you’re face to face.”

9. Stop the comparisons. Now.

“If you’re comparing new men to your old one and thinking, ‘Oh, you’re not as good looking as my ex,’ head right back to the first point on my list, because you aren’t over him!

“Just remember that the great thing about your new guy, whoever he is, is that he is NOT your ex!”

10. Give positivity a try. Honest.

“Treat the next person as if he was the only guy in the world and just look at him. Don’t look over your shoulder.

“If you really need to make comparisons, write down all the current guy’s virtues, remind yourself what this new guy’s got going for him and wipe the slate clean.”

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Source: Cosmopolitan.co.uk

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