Secret documents expose an advanced tax scheme. A company involved in building the flagship hospital New Karolinska is moving money to the tax haven Luxembourg. Foto: Ola Christoffersson

New Karolinska – advanced tax scheme in Luxembourg

Uppdrag granskning ·

It is called the flagship of Swedish health care. Top modern university hospital New Karolinska Solna. SVT program “Uppdrag granskning” (Mission: Investigation) can now reveal that large sums in the prestigious project is routed to the tax haven of Luxembourg.

Derricks rise over a huge construction site on a hill in northern Stockholm. Buildings of glass and steel take shape in one the most expensive projects in Sweden: New Karolinska Solna (NKS). A praised but also criticized project, where Swedish authorities in 2010 gave a single bidder the contract in a so called public-private partnership (PPP) – not only to build the hospital but also account for the financing and maintenance for decades to come.

– We know to the single Crown what this will cost. There are no surprises for the taxpayers. We have full control, there are no secrets. This project bears close examination, said Torbjorn Rosdahl, leading politician for the Conservative party ordering the NKS-hospital.

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What the politicians in the Stockholm county did not know, and did not ask about, is how much the project company Swedish Hospital Partners (SHP), owned by Swedish construction giant Skanska and British investment company Innisfree, should pay in taxes. And why there are subsidiaries in the tax haven of Luxembourg.

A few months after SHP in 2010 was awarded the NKS contract, worth at least 52 billion Swedish Crowns, the multinational auditing and consulting firm PricewaterhouseCoopers (PWC) was commissioned by Innisfree to create an advanced tax scheme in Luxembourg. This is detailed in new secret documents, reviewed by SVT, part of the big leak from PWC revealed by International Consortium of Investigative Journalists (ICIJ).

In the by now wellknown “Luxleaks” from PWC there are over 340 companies from around the world. Most of the 28 000 pages of the leaked database relate to advanced tax planning, detailed descriptions on how companies have channeled hundreds of billions of dollars through Luxembourg, saving billions of dollars in taxes.

– This is the first time really that we'd seen inside the workings of Luxemburg as a tax haven. The whole point of these documents is that they explain how these tax schemes work, says Richard Brooks, a former U.K. tax inspector and author of the book The Great Tax Robbery, who was hired by ICIJ to help review some of the leaked documents.

– Normally these companies would try to cover up what they're doing, but in these documents they're being very open about them. And that's very rare, to find companies explaining how they're doing their tax avoidance, of course they wouldn't do it publicly, but they'll do it for the Luxembourg tax man.

Sweden is on the top-ten list in the number of companies that are in the database. There are IKEA, Tele2, Swedish venture capital companies, food industry, hotels, healthcare companies. And there is also the company building top modern hospital NKS – Swedish Hospital Partners – equally owned by the Swedish construction giant Skanska and British Innisfree.

Broadly, the internal documents of the PWC show how the owners, through a number of subsidiaries, will lend large sums of money – to themselves. Skanska's share comes from companies in Sweden. But the money from Innisfree does not come from the UK, where Innisfree has its headquarters, but from Luxembourg.

Over half a billion Swedish Crowns is loaned from two companies that have offices at the same address in Luxembourg's financial district: JFKennedy-avenue, 46a. A search through the ICIJ database of the leaked PWC documents shows that about 1400 other companies at the very same address: letterbox-companies.

The two companies in Luxembourg: Innisfree Innisfree F3 and the ISF – lend money to Swedish Hospital Partners (SHP). SHP pays a high interest rate on the loan – 9 percent. This will reduce the taxable profits in Sweden, when the money is moved to Luxembourg. And the documents reveal an advanced tax structure where the tax result in Luxembourg is near zero.

What we see in the secret documents about the New Karolinska goes for many of the leaked documents. Money that would have been taxed for in a country, turns tax-free in another. This is called ”hybrid instruments”, and described as part of Luxembourg's business concept.

– Luxemburg offers two things to international companies. It offers an array of options for lowering taxes to very low levels, and even to not pay any tax at all. It also on the other hand, offers high levels of secrecy. So companies come to Luxembourg often not for real business reasons, but attracted by the ability to lower their taxes, says Nikolai Shillinglaw, at tax-watchdog organisation ASTM.

SVT program “Uppdrag granskning” (Mission: Investigation) has – along with several experienced experts – audited annual reports, contracts, reports and tax accounts in several countries of the companies involved in the owners' internal loans to the SHP and the construction of New Karolinska.

Conclusion: year after year until 2039 to be Swedish Hospital Partners pay interest to the letterbox-companies in Luxembourg. A total of around 1.3 billion Swedish Crowns will be channeled to Luxembourg – basically tax free. How much more tax Swedish Hospital Partners would had to pay in Sweden – without using internal loans from the Luxcompanies – is hard to calculate. Probably hundreds of millions of Swedish Crowns.

– It is offensive to see this. Especially after you know what an amazing win this project company already does. It simply sucks on pure Swedish, says Ilija Batljan, leading politican for the Socialdemocratic party, in 2010 when the NKS-contract was signed.

Confronted with the leaked documents, Torbjörn Rosdahl, the leading politician for the Conservative party, expresses frustration.

– When you talk about these huge sums, so I feel disappointed, because I believe that one should pay tax in the country in which one operate, and we need this money to extend the welfare in Sweden, says Torbjörn Rosdahl.

SVT has made repeated attempts to contact managers at Innisfree, but without result. They do not want to answer questions. Instead they respond in e-mails that Innisfree follow the law, and that Luxembourg is used for administrative purposes and does not affect the company's tax in the UK.

When confronted, Swedish Skanska put the blame on Innisfree.

– It's Innisfree who have made this arrangement, not Skanska. Skanska owns our share through a Swedish company, we pay tax in Sweden, says Hans Biörck, advisor at Skanska.

Hans Biörck was CFO at Skanska when Skanska and Innisfree in 2010 got the contract to build and maintain New Karolinska. He – and Skanska – says that the internal loans are legal, a way to get return, and that the price tag for New Karolinska had been higher without this loan structure. Skanska says it had no knowledge about Innisfrees tax schemes in Luxembourg, but that its subsidiary Swedish Hospital Partners has informed the Swedish Tax Agency who is behind the complicated corporate structure – and that it largely involves tax-exempt funds.

But Skanskas claims is difficult to control. When SVT tries to follow the money flow from Luxembourg it stops. The transparency is minimal.

When SVT visits the PWC office in Luxembourg the TV-team is more or less thrown out, and police called to the site.

The Swedish HQ of PwC writes in a statement that tax assignments are carried out in accordance with applicable laws. And that at PwC sees with great seriousness on the leak in Luxembourg, and therefore traced an employee who is suspected. And now reviewing their security systems.

At the Swedish PwC HQ the SVT reporters tries to get answers on the central questions of tax avoidance.

One gets the impression that it is more important for you to chase whistle-blowers than seriously answer to the concerns about the legal and moral aspects of helping companies with these advanced tax schemes?

– We have given our written comment that you got from me, and otherwise, I must refer to my colleagues at the PwC global communications department in London, says head of communications Martin Askman.

But in London there are no answers to be found.

– No, we don’t comment on our clients affairs. Obviously these documents which we say in the statement were illegally obtained from our offices, they are not documents for the public domain. We never comment on the interests of our clients so, no we wouldn’t be able to do that am afraid, says Mike Davies, Director Global Communications PwC London.

So, PwC gives no interview, not in Sweden, not in Luxembourg, not in London?

– No, we haven’t given any interviews on this anywhere.

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