Interests held by ABN AMRO in companies registered in 'countries with a tax-friendly climate’ can be generally categorised into four groups:
- Inactive (empty) companies that are in the process of being dissolved. These are mainly old, empty Prime Fund Solutions entities that were left over after the sale of Prime Fund Solutions (part of the former Fortis Bank Nederland) to Credit Suisse in 2011. This is by far the largest group of companies.
- Companies that own local office buildings (ABN AMRO offices) which are used by ABN AMRO.
- Companies owning and operating seagoing vessels. These are joint ventures with domestic or foreign clients of ABN AMRO that are active in the international shipping industry. As a partner in the joint venture, ABN AMRO holds a maximum of 50% of the shares in the joint venture, and often has a smaller shareholding. The joint ventures’ place of registration for tax purposes is not always the same as the jurisdiction in which they were first established. Taxes on the joint ventures’ income are generally low due to the application of a tonnage regime or other tax-friendly regime for seagoing vessels.
- Companies with banking activities and companies that manage investment funds for the private bank, among others. Taxes on any investment gains from investment funds are always imposed in the country of the person or entity investing in the fund. A German investor pays tax on his investment gains in Germany, a Dutch person pays tax in the Netherlands, etc., regardless of where the fund itself is registered.
ABN AMRO did not establish these companies for its own tax gain or benefit. The companies were established for Dutch and foreign clients and always comply with local and international laws and regulations, or they are inactive companies as referred to in category 1.
ABN AMRO never facilitates tax evasion. All companies have been reported to the tax authorities in the Netherlands. ABN AMRO does not have any ‘letterbox companies’.
The Dutch daily Het Financieele Dagblad published an article last year on companies in tax-friendly countries that are owned by banks. In response, the Dutch Parliament asked a series of questions, which were answered by the Dutch Ministry of Finance.