Oh dear

Cameron\’s former efficiency tsar, Philip Green, is equally efficient in the organisation of his tax affairs: he legally avoids paying millions to Revenue and Customs by paying himself in the form of a dividend to a Channel Islands company owned by his wife, Tina, who in turn is legally resident in the tax haven of Monaco.

Green isn\’t paying himself. His wife is the owner of the company. His wife gets the dividends from the company. End of.

Unless you want to get all anti-feminist and insist that wives are simply extentions of the husband economically and financially.

73 thoughts on “Oh dear”

  1. This issue is forever raising its head. Last I looked, no-one has ever proven Mr Green does not pay all applicable taxes. Neither does Mrs Green.
    All applicable taxes including any income taxes her country chooses to apply to residents.
    I suspect people are simply envious of a rich woman. And the guy she is married to.

  2. One imagines that Mrs G gives Mr G a sizeable chunk of that money, no? And gifts are tax-free in the UK, aren’t they?

    Sure it’s not illegal, but it is clever. Run a business in the UK making money off Brits – keep the profits booked to a shell company in a low-tax jurisdiction. Keep the legal natural person owner in a no-tax jurisdiction, and other, essentially beneficiaries of the income, can continue to live in a high-tax jurisdiction (ironically the one where all those profits are being made anyway) provided gifts are not taxed.

    It is obvious to all that this is a tax scam. Sure, a perfectly legal one. But one that does nothing to distance me from Ritchie’s point (and really, I don’t agree with anything else he says) that taxation should happen where the economic substance of the transaction takes place.

    I know we all hate tax but it is a reality of life. And it is wrong and immoral that someone should live in the UK off earnings from UK businesses and not pay any sodding tax on that income. It’s not fair on the rest of the sods in the UK who cannot escape taxation because they don’t and can’t have arrangements with tax haven-registered businesses and tax haven-resident close relatives.

  3. “It’s not fair on the rest of the sods in the UK who cannot escape taxation because they don’t and can’t have arrangements with tax haven-registered businesses and tax haven-resident close relatives.”

    Ah, crabs-in-a-bucket syndrome…

  4. It’s not fair on the rest of the sods in the UK who cannot escape taxation because they don’t and can’t have arrangements with tax haven-registered businesses and tax haven-resident close relatives.

    Sorry, what’s stopping you from packing your wife off to a tax haven and opening a business in her name, the profits of which get handed back to you in the form of gifts?

    You seem to think there is no downside to Green’s arrangement. Firstly, his wife will not be allowed in the UK for more than 90 days per year, something which will be somewhat of an iconvenience to family life. Secondly, if Green’s wife decides to file for divorce and walk away with the whole lot, there is nothing Green can do about it.

    That you chose different options, i.e. not packing your wife off overseas and attaching considerable financial risk to the strength of your marriage, does not make you morally superior over those that did. You could have done the same, but you chose not to. But let’s not pretend that Green is being treated any differently under the law than you are.

  5. Yes, it’s undoubtedly a tax scam. But that’s not a good reason for changing the law. One high-profile couple abusing the tax system is no justification for eliminating independent taxation of married women and the right of married women to own property. UK Uncut know not what they demand.

  6. I suppose my broader point is that when people say “other people can’t” what they mean is “other people don’t want to, because it is inconvenient”.

    If my wife was daft enough to live in the UK, she could quite reasonably enjoy a life whereby her husband, i.e. me, worked overseas earning a healthy tax-free salary (not quite true, but near enough and was the case for a while), and handed a large portion of that salary over to her to spend as she sees fit. Given repatriated capital is not taxed in the UK, I could also buy a house and buy the wife a Porsche to cruise around in perfectly legally. Would anyone have an objection to this?

    Because this is pretty much what Green is doing: living in the UK off the overseas earnings of his wife. If you consider how mnay millions of women the world over are living at home off the overseas earnings of their husbands, you’ll see it is not exactly an unusual arrangement.

    Everyone has the choice to arrange their affairs in this manner, but the husband (or wife) will likely have to live in a shithole, seldom return to the UK, and not see their spouse very much. If people don’t want to do that fine, but they shouldn’t get on a moral high-horse against those who do.

  7. @Tim Newman re JamesV

    There is something really serious stopping him.

    Not having a gynormous company making stonking profits and maybe the fact he can’t trust his wife as much as P. Green can.

    At our more humble level, each and everyone takes the tax allowance on the first part of their income, don’t they? That is tax avoidance (ukuncut style) on our scale. We don’t pay on all our income we take the relief available. (By the way as Timmy so frequently points out, the Treasury will accept donations)

    At every level, you pays your money and you make your choices. Personally, I couldn’t live in Monaco (not because I haven’t got enough money (I haven’t) but because its a dump) although less than 90 days in whinging, chip-on-shoulder, fact-ignoring, PC, degenerate, why do I have to get up to sign for my cheque?, UK gets easier by the day.

  8. @Frances Coppola: it is not a ‘tax scam’. It is the utterly legal (and moral IMO) application of the tax laws as they are currently written. Vast swathes of UK business are owned by foreigners, and profits (after corporate taxes) are remitted abroad in exactly the same way that Mrs Green receives her dividends. She does not live here, just like the shareholders in Thames Water (owned by an Australian investment fund). Why should she be treated any differently? The fact that her husband runs her business for her is no different to a shareholder who lives abroad and employs a CEO to run their business, which is effectively the case for every foreign based buyer of UK companies.

    Anyone can do what Mr & Mrs Green are doing. Set up a UK company in the name of a spouse, pack the spouse of to Monaco, and work like a dog here in the UK for the company owned by your spouse. All profits pay UK corporation tax, dividends then remitted to Monaco. Get on with it, no-one’s stopping you.

    Whats that? You don’t create as much wealth as Philip Green can (and did), so its not worth it? Ah, well there’s the issue isn’t it – he’s a lot better at making money than most people……………

  9. It’s a scam. He earns the money, she gets paid.

    We could change the law so that if one of a married couple is UK resident and domiciled for tax purposes, they both are. Perhaps the Greens would then get divorced.

  10. Set up a UK company in the name of a spouse, pack the spouse of to Monaco, and work like a dog here in the UK for the company owned by your spouse.

    Doesn’t even have to be Monaco. You can do the same from Dubai or Thailand for a fraction of the cost running, say, a recruitment agency for the global oil industry. This isn’t a case of the Greens only being able to do what they do because they make a lot of money, because anyone can do it in cheaper locations. It’s just most people, as you say, don’t think it’s worth it.

  11. It’s a scam. He earns the money, she gets paid.

    Ah, because being a woman she can’t possibly make any business decisions or be capable of earning money on behalf of the company, no she’s just some dolly-bird who is only involved for tax-avoidance purposes. Change the tax laws and she’d be back to being a receptionist, no doubt.

    When did the 1950s come back around?

  12. So both him and her are treated exactly as they should be by the UK tax system. And treated the same way as many other people, albeit with higher income than most who share money but live in different countries.

    I get job offers for work abroad, from which I could send money home to the wife (not small change either) – she could live quite nicely on what could be sent home. But I choose not to take those jobs, being away from home 6 months at a time is not something I want in a relationship. So we both stay here, subject to UK taxes on income, our choice and very glad I’m not Mr Green.

  13. We could change the law so that if one of a married couple is UK resident and domiciled for tax purposes, they both are.

    So if a Brit marries a foreigner, her earnings automatically become liable for UK taxation regardless of where she lives and works?

    What makes me laugh about these suggestions is that people always assumes it is their country which would benefit. Never do they consider that if a British man marries an Indian national (for example), then if India are playing by the same rules the Brit would now be liable for Indian taxes, despite never being there.

  14. Jim: you’re mistaken on one point: the Green’s company is Jersey-registered, and so doesn’t pay corporation tax.

    I suspect there’s no real disagreement here on the “scam” question: some say the arrangement is not a scam because it’s legal, others say it is a scam because it doesn’t reflect where the money really comes from. We’re just using slightly different meanings for the word, both of them valid.

    Tim adds: “the Green’s company is Jersey-registered, and so doesn’t pay corporation tax”

    Bollocks. Arcadia is UK registered, UK domiciled and pays UK corporation tax. The dividends then go to Taveta, which is indeed in Jersey and does not, as a non UK company, pay UK corporation tax. Which is hardly surprising, being a non UK company.

    And dividend income isn’t subject to corporation tax anyway as it’s already been charged to the first company in the chain.

  15. I suspect there’s no real disagreement here on the “scam” question: some say the arrangement is not a scam because it’s legal, others say it is a scam because it doesn’t reflect where the money really comes from.

    No, this is no more of a scam than a Filipino seaman working overseas tax-free repatriating money to his wife back in Manila. A partner earning tax-free overseas and repatriating money “home” is practised by millions of people the world over.

  16. It’s clearly a (perfectly legal) scam.

    I think it utterly morally wrong to base yourself overseas entirely in order to avoid paying taxes in the country that you have lived in for 50 years and which has provided the infrastructure for you to run a successful business.

    Mrs Green ran off to Monaco in the days when income tax was only 40% so she can’t even claim that tax rates were egregiously onerous.

    And UKUncut (who are wrong about most other things) do have a sound point that others can’t do what Mrs G has done, because you need a certain income to be able to live a family life in two separate locations.

    Of course my local plumber could send his missus off to live in Dubai (doubt they could afford Monaco) but they can’t afford to keep two houses and fund weekly plane tickets.

  17. Of course my local plumber could send his missus off to live in Dubai (doubt they could afford Monaco) but they can’t afford to keep two houses and fund weekly plane tickets.

    Right, but the plumber could afford to share an apartment in Sharjah, carpool into Dubai each morning, and go home twice per year. This is what most expats do there. That Green can afford to see his wife more often doesn’t make what he’s doing morally different from your plumber.

  18. Bear in mind also that Mrs Green became a Monaco resident just before Arcadia’s “special dividend” of £1bn+ was paid out.

    So you have twenty years of accumulated profits that could have been paid out as dividends, and UK tax accordingly paid, but these were saved up whilst the Greens had the benefits of living in the UK and then they hopped off overseas with their effectively tax free swag.

    It’s freeloading. Whatever good Philip Green has done by running a successful and job creating business it doesn’t excuse him arranging things so that the Green family personally pay little tax.

  19. @Tim Newman

    You completely misunderstand.

    Most expats working in Dubai do so because that’s where the work is. No one is objecting to that. It isn’t Philip Green who is working in Monaco, he is working in the UK.

    We are talking about moving your non-working spouse to a zero tax location and channelling your earnings through her.

    ie. I get my leaking tap fixed by Mr Plumber, invoiced by Notting Hill Plumbers (wholly owned by Mrs Plumber (Dubai)).

  20. Perhaps Mrs Green enjoys life in Monaco. I have never lived there although I have visited it a few times and to a degree agree with the opinion expressed above that it is a shithole, although obviously the weather is good. I think I would say that above all it seems to me to be boring in comparison with the life available elsewhere (to a person of modest income like me who is not partying on super yachts), but choices are made and everyone has their primary goals to achieve.

    However, I would venture to guess (I have no evidence for this) that Mrs Green is of similar mindset to Leona Helmsley – “only the little people pay taxes” – and the only substantial difference between them is that Helmsley was evading, Green is avoiding.

    Am I envious, of Mrs Green’s wealth? Yes.

    Am I envious of (what appears to me to be) her primary motivation to maximise her wealth and what she chooses to do to achieve that? No – in fact I regard it as rather repugnant.

  21. I think the real difference here is between those of us who are content to pay taxes but want them to be applied fairly and so find the Greens’ arrangements distasteful, and those who dislike taxation in general and so applaud any method of tax avoidance.

    Tim: it’s a bit harsh of you to describe my statement “The Greens’ company is Jersey-registered and so doesn’t pay corporation tax” as “bollocks” when the Greens’ company, Taveta, is in fact Jersey-registered and does not pay corporation tax. But I take your point about Arcadia.

    Tim Newman: sorry, you are quite right, there is some disagreement. What I should have said is “there is no real disagreement here on the ‘scam’ question among the majority who are capable of seeing a difference between Tina Green’s tax affairs and those of a Filipino seaman.”

  22. Most expats working in Dubai do so because that’s where the work is.

    Not really, and this is coming from an expat who lived there for 3 years. I wouldn’t say it is any easier to find a job in Dubai than it is in the UK, and is probably a lot harder. Most people go there for the opportunity to live abroad in a holiday resort and to take advantage of a few years of tax-free salaries. There’s nothing really done in Dubai that isn’t done elsewhere, only you do find recruitment and financial consultants basing themselves there because they know they can attract people – who are looking for tax-free salaries.

  23. Paul B:

    “I think the real difference here is between those of us who are content to pay taxes but want them to be applied fairly and so find the Greens’ arrangements distasteful, and those who dislike taxation in general and so applaud any method of tax avoidance.”

    Very well said.

  24. “there is no real disagreement here on the ‘scam’ question among the majority who are capable of seeing a difference between Tina Green’s tax affairs and those of a Filipino seaman.”

    We can all see a difference, only some of us realise that it is a difference only of degree and not form. Therein lies the disagreement.

  25. We are talking about moving your non-working spouse to a zero tax location and channelling your earnings through her.

    Mrs Green was a non-working spouse? Where are you getting this from?

  26. @Tim Newman (22)

    You are still missing the point (I think). The discussion isn’t about working in a zero tax location. I’m well aware that people choose to work in the Middle East or Asia because of the weather, the ex pat life style, a change of scene, being able to weekend in Bali as well as the low tax and job opportunities.

    The issue is about deliberately relocating your non-working spouse to a low tax location in order to avoid tax on the overall family income.

    I can’t see any reason for Mrs G to be a Monaco resident other than to avoid tax. She could just as easily continue to be a UK resident and still spend most of the year on yachts anywhere in the world.

  27. “Mrs Green was a non-working spouse? Where are you getting this from?”

    Common knowledge I thought. I am not aware that Mrs Green has had any executive (or other) input into the success of Arcadia.

    If I’m wrong about this I apologise. But I was fairly certain Arcadia’s success was down to Philip Green.

  28. The issue is about deliberately relocating your non-working spouse to a low tax location in order to avoid tax on the overall family income.

    Right and at this point I’m going to ask for evidence that she was a non-working spouse, presumably who offers nothing of value to the business?

    And in what way is a somebody moving to Dubai to work tax free not “avoiding tax on the overall family income”?

    I can’t see any reason for Mrs G to be a Monaco resident other than to avoid tax.

    I think this says more about the limitations of your imagination than anything else.

    She could just as easily continue to be a UK resident and still spend most of the year on yachts anywhere in the world.

    Where’s your evidence she spends all her time on yachts and doesn’t work within the companies she owns?

    There’s some seriously sexist shit coming out in this discussion.

  29. “And in what way is a somebody moving to Dubai to work tax free not “avoiding tax on the overall family income”?”

    Because their job is in Dubai. If you are a plumber in Dubai you pay Dubai taxes.

    We are talking about doing a job in one country but basing yourself in another.

    “I think this says more about the limitations of your imagination than anything else.”

    Well, what are the other reasons then. Why does she have to be resident in Monaco for other than tax purposes ? No one is stopping her having a house there, or spending most of the year there if her friends are there, but why does she have to take up tax residency ?

    “Where’s your evidence she spends all her time on yachts and doesn’t work within the companies she owns?”

    Sorry, you are just being stupid now. I’ve read enough about Philip Green over the years to have seen scant evidence that his success has relied on any but his own efforts (with hat tip to Kate Moss for design).

    As I said before if I am wrong about Mrs Green’s input then I apologise but I have seen no evidence that she plays an active role in the business.

    The fact that Philip Green isn’t Monaco resident, as I assume he has to be in London frequently enough to run the actual business, does rather suggest he is in charge.

    The same argument applies equally to a business run by a woman with a non-working husband, so please stop the sexist insinuations.

  30. Because their job is in Dubai. If you are a plumber in Dubai you pay Dubai taxes.

    Right, and if you are a businesswoman in Monaco you pay Monaco taxes which, like in Dubai, are zero. Struggling to see the difference here.

    Well, what are the other reasons then. Why does she have to be resident in Monaco for other than tax purposes ?

    Oh, so now I have to make up for the deficiencies in your imagination which are the root cause of your complaint? Okay, I’ll bite. For a start, separating ownership and operatorship between individuals and jurisdictions minimises risk; secondly, Tina Green is South African born and probably thinks – as a lot of foreigners do – that Britain is a shithole. For all we know, she might have hated the place from the moment she got there but wanted to be close to her husband when his business was being built, and left as soon as she got the chance. She certainly doesn’t have any obligation to stay in the UK. Thirdly, why Monaco? Nice weather, close to France, plenty of English spoken. Where else is she going to go?

    Sure, tax minimisation would have played a major role in this, but it does with the decisions of every family who has made the decision for one or all of their members to move abroad for any reason. Retirees who move to Thailand consider tax, and attempt to minimise them. My decision to move to Dubai was partly based on tax, my decision not to move my wife to the UK was partly based on tax, the decision of Australians to return home from working in Russia are consider tax as a factor.

    Nobody is saying that the Greens aren’t deliberately minimising their taxes. My point is that what they are doing is no different to millions of other people both rich and poor, and that when you make a decision to move abroad and choose a location and family arrangement, there is a lot more to it than just taxes. I’ve lived in 5 countries in 9 years, worked in 4 of them, been resident for tax purposes in those 4 plus another 1. Yes, when I thought about where to buy an apartment and install my wife I considered tax – you’d be mad not to – but that wasn’t the only consideration (political risk played a huge role), and it’s a huge assumption to be able to take one look at the decisions of people you’ve never met and think you know why they have moved to a particular place.

    Sorry, you are just being stupid now. I’ve read enough about Philip Green over the years to have seen scant evidence that his success has relied on any but his own efforts

    Right, but how does this equate to her having no role in the companies she owns? My employer can quite reasonably say that their success is not much down to my efforts, but that’s quite a bit different from saying I play no role whatsoever in the company.

    The fact that Philip Green isn’t Monaco resident, as I assume he has to be in London frequently enough to run the actual business, does rather suggest he is in charge.

    Yes, he is. He’s the CEO. But I am not convinced that a majority owner of these businesses sits back and takes no interest. After all, we hear all the time from the left that the CEOs of Murdoch’s companies are sock-puppets who take their orders directly from the owner, so why the assumption that Green’s wife is told to belt up and do what she’s told?

    The same argument applies equally to a business run by a woman with a non-working husband, so please stop the sexist insinuations.

    It is your immediate assumption that she does no work and the sneer that she spends all her time on yachts which is sexist. I very much doubt you would have said this had he passed the ownership to his brother.

  31. Remember also that Mrs Green has owned Arcadia for years, long before it became as valuable as it is now.

  32. Shinsei67 (#18) said:
    “Mrs Green became a Monaco resident just before Arcadia’s “special dividend” of £1bn+ was paid out … twenty years of accumulated profits … saved up whilst the Greens had the benefits of living in the UK”

    Wrong.

    Lady Green emigrated to Monaco in 1998. Her company, Taveta, didn’t buy Arcadia until 2002. The special dividend was 2005.

  33. Last I looked she was a shareholder. What law requires a shareholder to work in the companies they own shares in? Not saying she doesn’t work – I daresay she has considerable input into policy decisions, as you’d expect from a majority shareholder risking their own money in a business.
    But is there any requirement that a shareholder MUST work for a particular business?

    Seems to me as a foreign national she can live where she wants. And the company is not required to give dividends in any one year is it?

  34. “Lady Green emigrated to Monaco in 1998. Her company, Taveta, didn’t buy Arcadia until 2002. The special dividend was 2005.”

    So a foreign resident purchased a company and a few years later received a dividend from the company. Is she treated exactly the same as any other foreign resident doing the same actions, yes or no?

  35. Tim Newman:

    “Right, and if you are a businesswoman in Monaco you pay Monaco taxes which, like in Dubai, are zero. Struggling to see the difference here.”

    No one is disagreeing with that. However the Greens evidently have a spousal relationship whereby the business is run in London by Philip (hence reason he can’t be Monaco resident) and yet the majority of earnings from Arcadia are channeled tax free to Tina Green.

    I’m not objecting to Tina Green running any other business out of Monaco and paying Monaco taxes on that.

    “Oh, so now I have to make up for the deficiencies in your imagination which are the root cause of your complaint? Okay, I’ll bite.”

    None of your three reasons necessitate her being tax resident in Monaco. She can live in pleasant Monaco and speak French without taking Monaco citizenship. She think’s UK is a shit hole, well, she still has her South African passport I assume.

    “Right, but how does this equate to her having no role in the companies she owns? ”

    I, of course, realise that Tina Green has almost certainly played a valuable role in her husband’s business success. However it is clearly his business, he used to own 100% of it, and then, whoosh, it is suddenly 100% her business.

    “It is your immediate assumption that she does no work and the sneer that she spends all her time on yachts which is sexist. I very much doubt you would have said this had he passed the ownership to his brother.”

    Oh come on. Monaco ? It’s all about yachts. That’s what people do there. I could have made the other cliche about spending all day in the casino. If she were younger I might have mentioned spending all day with her tennis instructor.

    The Greens are well known party people. Hence it wasn’t unreasonable to assume she spent a lot of time partying.

    Sure, she might spend all day running charities, and if so I apologise. However I would urge her to not avoid tax first.

  36. “So a foreign resident purchased a company and a few years later received a dividend from the company.”

    Ownership was transferred I assume. Where did Tina get the money to buy Arcadia ?

    She’s not managing her SIPP in Monaco, buying Imperial Tobacco shares, and then pleasantly discovering they are issuing a special dividend.

  37. James V: But one that does nothing to distance me from Ritchie’s point (and really, I don’t agree with anything else he says) that taxation should happen where the economic substance of the transaction takes place.

    Well, another view on this: Lady Green, by living abroad, reduces her benefits from British taxes. Except when visiting, she does not drive on British roads or catch British trains, she is not protected by British policemen, she does not benefit from the massive social cohesion created by British government social spending (I am basing this on comments by the Guardian and the like about how the government’s deficit reduction plans are going to lead to rack and ruin).

    Compare this with a person living in Britain, earning all their money abroad, but doing all this and perhaps sending their kids to state schools, getting treated at NHS hospitals etc. Under Ritche’s point, if applied to things like income tax, they would pay no tax in Britain despite benefitting from British public spending. Is this fair?

    Note, from what I understand of Monaco’s system, which isn’t much, Lady Green may well be benefiting substantially from French public spending to which she does not contribute via taxes.

    And it is wrong and immoral that someone should live in the UK off earnings from UK businesses and not pay any sodding tax on that income.

    How are they avoiding paying VAT?

    Given that we don’t have a world government, I don’t think any tax system can avoid some situations in which people in similar situations are treated differently. There are substantial problems with taxing people differently based on whether they are married or not (I heard that in the US some couples in the 1970s used to get a divorce just before the tax day, save thousands, then remarry the day after), and also in ignoring marital status. There are substantial problems in taxing based on where the money was earned, and on where the people live. There are always going be cases that can be described as wrong and immoral.

  38. And there was I, thinking that for anywhere to be liveable, a place where people actually choose to live, the government of that place had to confiscate about 50% of the population’s wealth. Who knew it could be otherwise?

  39. None of your three reasons necessitate her being tax resident in Monaco. She can live in pleasant Monaco and speak French without taking Monaco citizenship.

    Erm, you are taxed where you are resident. If Mrs Green lives in Monaco, she is taxed as a Monaco resident.

    She think’s UK is a shit hole, well, she still has her South African passport I assume.

    So what, you think any natural born South African who wishes to leave the UK should only be allowed back to South Africa? Shouldn’t be allowed to consider Monaco?

    Oh come on. Monaco ? It’s all about yachts. That’s what people do there

    That’ll be news to those who work for SBM, who incidentally offered me a job. Strangely, they didn’t mention yachts being part of the package.

  40. Shinsei, Arcadia was never owned by Philip Green.

    Before Taveta bought it in 2002 it was a quoted company, with a broad range of shareholders; so far as I can find out neither of the Greens had any involvement in it before 2002.

    In the 2002 takeover it was bought directly by Tina Green’s Taveta investment company. Claims that it was bought by Philip Green and transferred to his wife are incorrect; the ownership of Taveta was fully disclosed in the takeover documents at the time.

    Where did the money come from? I’d have to check, but didn’t the Barclay Brothers (resident in Sark) put up a lot of it, presumably a very profitable investment for them.

  41. JamesV (#2) said:
    “it is wrong and immoral that someone should live in the UK off earnings from UK businesses and not pay any sodding tax on that income”

    Who are you talking about?

    If you mean Sir Philip, he’s paid a large (£million plus) salary for running Arcadia, and pays UK tax on that.

    If you mean Lady Green, she doesn’t live or work in the UK.

  42. @Tim Newman

    “Erm, you are taxed where you are resident. If Mrs Green lives in Monaco, she is taxed as a Monaco resident.”

    Nope, you are taxed where you are tax resident.

    You may have noticed that multi-billionaires tend to have different lifestyles to most other people.

    Tina Green, might easily spend as far as I am aware, two months in London, two months in Barbados, two months in Chamonix, two months in Tuscany and four months in Monaco.

    I’ve no idea what she calls “home” but she will reside in several places. But she has chosen to be tax resident in Monaco.

    So again I repeat it is highly unlikely that she chose to be tax resident in Monaco for any other reason than to pay less tax.

    There is nothing stopping her remaining a UK tax resident and spending all year overseas.

    If she divorced her husband I would have no problem with her receiving dividends and paying Monaco taxes on them. But the Greens have clearly set up a scam where by transferring ownership of his entire company to his tax haven wife the Greens (as a spousal couple) avoid 100s of millions of UK tax.

    And I’m sorry SBM never mentioned a yacht. But then you evidently don’t move in the sort of circles the Greens do where they spend $1m on hiring Elton John (or whoever it was) for a 60th birthday party.

  43. And it is wrong and immoral that someone should live in the UK off earnings from UK businesses and not pay any sodding tax on that income.

    This is just not what’s happened. As TW has pointed out earlier.. Arcadia pays UK corporation tax and, as far as I’ve made out from the accounts I’ve looked at, pays it broadly at the headline rate.

    I don’t know if Phillip Green draws a salary as CEO.. but if he does then he’ll pay UK tax on that salary.

    So the earnings of the business, which happens in the UK, are taxed in the UK. The earnings of the CEO, who works in the UK, are taxed in the UK.

    The post-tax distributions to the owner of the business, who is not based in the UK, is not taxed in the UK.

    It’s one thing to say that they shouldn’t be allowed to do what they’ve done, but how about people at least stick to the facts? Despite a number of people on this thread pointing out the established truths, some people are still spewing out the UKUncut version. There really is no excuse for that.

    Everyone is free to disagree on whether something should be allowed, or whether something is done for one reason or another… but get the facts right.

  44. Shinsei67 said (#43) “transferring ownership of his entire company to his tax haven wife”

    As I said above, #41, Arcadia wasn’t transferred to Tina Green.

    Philip Green never owned it. Not even for a minute.

    It was stock-market quoted, with no Green involvement, until 2002, when it was bought by Tina Green’s Taveta investment company.

    All disclosed in the takeover documents at the time.

  45. The Thought Gang

    Who is spewing out UKUncut nonsense?

    Everyone here (as far as I am aware) accepts that Arcadia pays corporation tax in the UK as it should. And that Philip Green pays income tax here on his £1m salary.

    And everyone (as far as I am aware) accepts that Tina Green has every legal right to be tax resident in Monaco and pay Monaco taxes on the dividend income from the second largest retailer in the UK that she just happens to find herself the owner of.

    What people such as myself object to is the fact that she chose to base herself in Monaco primarily as a way of avoiding 100s of millions in tax that would have ensued had she been a UK tax resident.

  46. I’ve no idea what she calls “home” but she will reside in several places. But she has chosen to be tax resident in Monaco.

    So you have no idea where she lives, but you are somehow quite sure it is not Monaco and she spends so little time there that she should not be considered tax resident based on it? Yeah, I’m convinced.

    There is nothing stopping her remaining a UK tax resident and spending all year overseas.

    There’s nothing stopping any expat doing that either, but why the fuck would they? You base yourself where it is most convenient and pleasant for you, trading various things off against one another, one of which is tax.

    But the Greens have clearly set up a scam where by transferring ownership of his entire company to his tax haven wife the Greens (as a spousal couple) avoid 100s of millions of UK tax.

    And you have arrived at this conclusion by making assumptions which are based on nothing, e.g. Tina Green’s contribution to the companies, the amount of time she spends in Monaco, her lifestyle when she’s there, and the reasons for her choosing it. If you are going to make up a load of shit and then get angry about the conclusions you draw from it, that’s up to you. Me, I don’t get angry over stuff I’ve just dreamt up.

    But then you evidently don’t move in the sort of circles the Greens do where they spend $1m on hiring Elton John (or whoever it was) for a 60th birthday party.

    What’s this got to do with anything? Chris Gent once hired The Corrs to play at a Vodafone bash, yet he stubbornly stays resident in the UK. Hey, you know what? Maybe Tina Green living in Monaco has nothing to do with who plays at her parties? Now that’s a radical idea!

  47. What people such as myself object to is the fact that she chose to base herself in Monaco primarily as a way of avoiding 100s of millions in tax that would have ensued had she been a UK tax resident.

    Yes, and my point is that this is what millions upon millions of people do the world over: go to Dubai and you’ll find thousands upon thousands of people doing precisely that.

  48. Shinsei67 (#46) said:
    “What people such as myself object to is the fact that she chose to base herself in Monaco primarily as a way of avoiding 100s of millions in tax that would have ensued had she been a UK tax resident.”

    Why the hell should she live in the UK at the cost of 100s of millions of pounds?

    This is a genuine question. What possible moral claim does the UK have that she should stay here and pay tax?

    Unless you go back to something rather like feudalism (Philip Green is a vassal, and by marriage to him she has become a vassal too), I really can’t see it.

    Paying tax here when you’re living here, or the company paying tax on its profits earned here, I can see there’s a valid argument there. But what possible argument is there that Tina Green has a moral duty to voluntarily become tax-resident in the UK?

  49. She has no requirement to become a UK tax resident.
    And like with millions of other shareholders across the world, the UK government has no claim on HER income. His income I expect is as subject to tax as anyone else in Britain. But his income and her income are not the same.
    She chooses not to be resident here, she chooses not to therefore be liable for tax here – her decision.
    As has been said, she doesn’t get the benefit of UK services herself, why would she want to pay hundreds of millions of pounds? What would she get out of the deal?

  50. Indeed. What ethical proposition is being advanced that it is morally wrong to seek to reduce the confiscation of the fruits of one’s labour, or the confiscation of one’s property?

    The fruits of my labour, and my property, are mine. I do not hold them on sufferance.

  51. So everytime I decide to buy a M&S off-the-peg, I am choosing to stuff inland revenue because I don’t have a hand-made at 5 times the cost (which actually I can afford) and the loss in tax to the government is somehow a scam.

    Ever bought duty-free? Back in the days..

    If your tax code allows mortgage relief, do you take it?

    But underneath all this is the basic 21st century left – right divide.

    Left
    You owe your success to society and what it has given you. It is society’s right and society’s right alone, to decide how much you are allowed to keep and how much is devoted to making society fairer in (material) outcomes and more progressive (slight cough). Society should and will take most of the big decisions regarding health, safety, education, etc as that is its job and will take any measures necessary to ensure that you comply with what is decided (I could add: ‘by your betters’, but then you would know where I stand, wouldn’t you?). The right are greedy baby-eaters to a man (ok and woman) and have no social morals, believe in privilege as a right and screw the rest.

    Right
    I work, I earn, I respect the rules, accept that my rights terminate when they bump up against those of others, I pay tax but I am a free man (ok or woman) and I take maximum responsibility for my life and I take all the decisions which affect my life (which haven’t been taken away from me) including organising my affairs in any legal way I want. I choose how, when, why and in what way I work and play and nobody has the right to tell me what to do if I am not infringing the laws of the land or the rights of others. The left are authoritarians unworried by basic economics with a guilty conscience and dedicated to doing the greatest damage possible by trying to do good.

    Rogues and scum abound throughout both sides and shouldn’t be considered representative.

  52. Even if Tina Green was UK-resident, she is not UK-domiciled, so certain tax planning options would still be open to her.

  53. “But what possible argument is there that Tina Green has a moral duty to voluntarily become tax-resident in the UK?”

    To be fair she was tax resident here first and has chosen deliberately not to be. So she has made a conscious decision to contract out of obligations that she knew she would be subject to.

    Having lived in the UK for many years, her children growing up here, her husbands business being based in the UK and benefiting from all the things the UK provides (like police to keep UKUncut away from front door) and holding a UK title.

    And even if you consider she owes the UK nothing she is clearly aiding her husband avoiding tax that he would have to pay had the billions in Arcadia dividends been paid out to him.

    The Green family thus get their yachts and extravagant birthday parties paid for tax free.

    I just don’t think it right.

  54. Tim Newman

    “Yes, and my point is that this is what millions upon millions of people do the world over: go to Dubai and you’ll find thousands upon thousands of people doing precisely that.”

    Yet again you are just being obtuse.

    I know Dubai perfectly well, and Singapore and Hong Kong. Full of people working very hard doing a job, being paid there, and paying (little) tax there.

    No one has a problem with that.

    Tina Green however is not working in Monaco. She does not run Arcadia. Her husband does. She has, though, effectively been gifted Arcadia by her husband. And thus it is a tax avoidance scam for them as a couple to take large dividends out of the company effectively tax free.

    Philip Green runs the risk, of course, that Tina runs off with his company. But assuming that doesn’t happen he gets to benefit from the success of Arcadia tax free.

    Your pedantry about why she chooses to live in Monaco fails the simple Occam’s razor test. The most logical reason for her being there is to avoid tax.

    I fail to see why this is in any way an admirable or laudable thing to do.

    It’s perfectly legal but it is a petty, selfish and dishonourable way of acting.

  55. You are ALL missing the point. Especially you, Jim.

    I don’t give a STUFF whether the Greens’ tax arrangements are an elaborate (though perfectly legal) scam or simply a sensible way of organising their affairs. I care about the damage that would be done to the rights of women if UK Uncut got their wish for the law to be changed so that Philip Green could be taxed on his wife’s income. Married women have the right to own property and to be taxed on their own income independently of their husband. Those are rights that were fought for over many years. And UKUncut want to eliminate those rights because of one high-profile couple who may be abusing them. It’s much too high a price to pay.

  56. Tina Green is not (and never was) a UK citizen. The UK has zero legal or moral right to any of her earnings, once she leaves the UK.

    Why do people seem to think that if you just once set foot on the hallowed ground of Britain, your entire future earnings are somehow ripe for the plucking?

  57. @Frances Coppola:

    scam: a fraud, a swindle, a con. To gain advantage by deceit.

    How does that describe the entirely legal activities of the Greens?

    The logical conclusion of the separate taxation of husbands and wives is what the Greens have done. You can’t have one without the other. A wife cannot be considered an independent agent (for tax purposes) up to a certain level of wealth, but above that line is a mere chattel of her husband (or vice versa). Its one or the other, no if, buts or maybes.

    Make your mind up what you want – independence, or a return to subservient status, for women (in the majority of cases). Then accept the consequences of your decision.

  58. I know Dubai perfectly well, and Singapore and Hong Kong. Full of people working very hard doing a job, being paid there, and paying (little) tax there.

    Yes, people who have left the UK to work in another country to avoid having to pay UK taxes on their enterprises. Which is what Tina Green has done. Your only objection is that you don’t think she works, and for that you have no evidence but some sexist assumptions and bullshit about yachts.

    Tina Green however is not working in Monaco. She does not run Arcadia. Her husband does. She has, though, effectively been gifted Arcadia by her husband.

    These are all pure assumptions on your part.

    Your pedantry about why she chooses to live in Monaco fails the simple Occam’s razor test. The most logical reason for her being there is to avoid tax.

    Yes, and most people assuming I own an apartment in Thailand for the cheap hookers passes the Occam’s razor test. Doesn’t mean that Occam’s razor is always correct though, and if you know a bit about why and how people choose where to live overseas, you’d understand that.

    I fail to see why this is in any way an admirable or laudable thing to do.

    Me too. But I also fail to see what the fuck business it is of anybody’s except Mr and Mrs Green.

  59. Oh come one guys, what the Greens have done is legally correct but morally questionable. I don’t have a problem with that dichotomy. Both positions are correct.

    What is fanciful is the contention that Mrs Green is the origin of the financial rewards which she has enjoyed. Private Eye has usefully listed many public statements by Philip Green on an “I did this” and “I did that” basis, which legally speaking should have said “my wife did this” or “my wife did that”.

    So there’s clearly a disconnect between a commonsense view of the situation and a strictly legal interpretatation.

    What I do find odd is that in this instance Mr Worstall sides with the legalistic view, but in any matters concerning Brussels he prefers to side with commonsense. This is not a coherent position.

  60. Why do people seem to think that if you just once set foot on the hallowed ground of Britain, your entire future earnings are somehow ripe for the plucking?

    Once again, crazy notions that exist in the USA are making their way over here …

  61. @60 CR

    Ermm as CEO of Arcadia he can say ‘I did this and that’ – because he did. The major shareholder just holds the shares, otherwise the government which owns >80% of RBS would have t say ‘we did’ – and they specifically distance themselves from day to day operations.

    Legally speaking he doesn’t have to say ‘my wife di this’ at all, just as RBS doesn’t.

  62. ‘I did this’ – a bloke claiming credit for what his family have done as well as what he himself has done?
    Fair play to the guy, he has done a lot. Whether his wife helped him or not is besides the point – she’s not subject to UK tax – and she has shares she can receive dividend on.

  63. Jim

    I really don’t care whether their affairs are legal or not. Or moral, for that matter.

    I care about the legal rights of women and I object to UKUncut’s attempt to undermine them.

    I could hardly have made myself clearer.

    You are preaching to the converted. Go and address your remarks to UK Uncut, not me.

  64. @Churm Rincewind: “What is fanciful is the contention that Mrs Green is the origin of the financial rewards which she has enjoyed”

    Well its a well known argument that is used by divorce lawyers to demand 50% of the wealth created by (usually) men on behalf of their (usually) wives. That such men could never have managed it without the guiding hand of their wife in the background. Personally I think that argument is b*ll*cks but try arguing it in the Guardian and see how far it gets you.

    I bet if Philip Green did own Arcadia outright himself and got divorced the same people arguing now that Tina Green has had no input into creating the wealth she owns (and therefore shouldn’t be considered the true owner) would then be arguing she deserved 50% of it because he couldn’t have done it without her marital support…………………….

  65. I think we can even keep Frances Coppola happy. As Mrs G is not UK resident, her earnings are rightly (legally, morally) free of UK tax. As Mr G is UK resident, his earnings are rightly (legally, morally) taxed in the UK.

    So, if we are to treat two halves of a married couple as entirely separate individuals for tax purposes because that’s kind to women, all we have to worry about are “not-earnings”. The cash and chattels Mr G receives from the kindness of Mrs G’s heart. Simply make these declarable, UK-taxable income. This can easily be done in such a way that you do not hurt women in general (it’s a given a “Tina tax” is going to hurt Tina) – for example such gifts would not be subject to taxation as the recipient’s income if they had already been taxed as the donor’s income (i.e. in the case of the vast majority of ordinary couples who actually live together in the same tax jurisdiction). Whether this can be done legally under EU law (as you’re treating income from one EU country differently from another), I don’t know.

  66. In the rush to defend the Greens’ efficient tax arrangements on the basis that the rich and well-connected obviously need all the help they can get from poorer people who actually pay tax, everybody has missed Mr Chakrabortty’s main point that it is insufferable that rich bastards get to write government reports because they are thought so wise and superior.Green may be able to avoid tax but he knows nothing about government waste which he was invited to pontificate about- with fuck-all insight as it happens.The unions could have done a better job.Come to that a John Lewis-type partnership would do a better job of running Green’s shops.

    Carry on defending the indefensible!

  67. DBC Reed

    “A John Lewis-type partnership would do a better job of running Green’s shops”

    Generally speaking the people who buy their clothes in Top Shop can’t afford John Lewis. Partnership doesn’t come cheap.

  68. dbc, you don’t think the unions are themselves involved in government waste? When was the last time a union called for staff cuts due to over-employing people?

  69. A partnership could easily be adapted to a cheaper form of retail.Round here the most efficient and popular convenience stores are run by the Co-0p.
    I was once a union official in the midst of “restructuring”.The consultants decided to get rid of whole swaths /grades of management.We workers took a very philosophical view of these job losses.
    The view of people like Green in this neck of the woods is that they are sole traders paying people cash out of their back pockets.The ideas of JD Burnham that, Capitalist or Socialist ,societies
    would everywhere be taken over by managers appears altogether too avant garde . I would have thought that workplaces where all work stations are computer linked would have even less use for managers .Libertarians and socialists should combine to get rid of managers.

  70. Popular the co-op may be, not necessarily most efficient. Round here its Tesco thats most popular. Efficiency I’ve not checked at any store but not found any supermarket obviously overstaffed.

  71. The co-op convenience stores (not supermarkets) round here are more highly staffed with two or three people on check-outs: Tescos have opened an automatic self swipe store.
    Would n’t want to hand out advice to Green on the schmutter trade; neither should he lay down the law about anything outside his very limited area of expertise.Which was Chakrabortty’s point.
    Did you see captain of industry ,John Moulton, explaining to Paul Krugman that the Nobel Prize winner did n’t understand anything about Economics on Newsnight?Really embarrassing.
    Business people like him Green and Beecroft should keep their saloon bar opinions to themselves.

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