Nando's restaurant group – ultimately owned by Dick Enthoven, a South African tycoon – uses a battery of offshore techniques, including companies in Malta, Guernsey and the Netherlands, to legally reduce its UK corporation tax bill by up to a third with a secretive £750m trust located in a Channel Islands tax haven at the top of the elaborate offshore web.
Buy a portion of spicy chicken thighs at Nando's and the cash flows into a network of accounting devices, involving Malta, the Isle of Man, Guernsey, the Netherlands, Ireland, Luxembourg, Panama and the British Virgin Islands. Profits finally fetch up in Enthoven's Taro III Trust. It is based in Jersey and has been operated by Kleinwort Benson. This trust, not liable for UK tax, contains no less than £750m and possibly much more.
One of the fruits of these manoeuvres turns out to be a classically English country estate, Spye Park in Wiltshire. The estate, which goes back to the 16th century, is occupied by Dick Enthoven's son. But the registered owner of Spye Park is actually an anonymous British Virgin Islands offshore entity.
The 280 UK restaurants last year paid over £21m of its revenues as a royalty for using the Nando's brand name. The money goes to a low-tax Netherlands entity called Tortolli BV. Tortolli in turn collects the cash on behalf of another company registered in another tax haven , this time in Malta. Rent for the restaurants is paid to a separate UK company, itself also owned by a Netherlands intermediary. In addition, the financing to fit out each restaurant comes through Channel Island loans, with £5m in "finance charges" last year moved offshore to an entity in Guernsey, called Nando's Leasing Ltd. The chicken business profits ultimately flow to a Luxembourg low-tax registered partnership. Accounts show the Luxembourg entity then pays cash over to the tax-free Jersey family trust as interest on a £750m loan.
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