Journalists publish leaked advance rulings and tax returns, conclude that Luxembourg aids tax avoidance

The International Consortium of Investigative Journalists (ICIJ) on November 5 published confidential tax documents of PwC clients on the Internet accompanied by a series of news stories that conclude that Luxembourg has been a long-time partner in multinational corporation tax avoidance.

The leaked documents include 548 Luxembourg advance rulings, or comfort letters; corporate tax returns of Luxembourg-based subsidiaries of MNEs; and other sensitive documents.

A group of  80 ICIJ reporters analyzed the leaked documents for the project, which lasted six  months. The ICIJ lists its major findings, as follows:

  • Pepsi, IKEA, AIG, Coach, Deutsche Bank, Abbott Laboratories and nearly 340 other companies have secured secret deals from Luxembourg that allowed many of them to slash their global tax bills.
  • PricewaterhouseCoopers has helped multinational companies obtain at least 548 tax rulings in Luxembourg from 2002 to 2010. These legal secret deals feature complex financial structures designed to create drastic tax reductions. The rulings provide written assurance that companies’ tax-saving plans will be viewed favorably by Luxembourg authorities.
  • Companies have channeled hundreds of billions of dollars through Luxembourg and saved billions of dollars in taxes. Some firms have enjoyed effective tax rates of less than 1 percent on the profits they’ve shuffled into Luxembourg.
  • Many of the tax deals exploited international tax mismatches that allowed companies to avoid taxes both in Luxembourg and elsewhere through the use of so-called hybrid loans.
  • In many cases Luxembourg subsidiaries handling hundreds of millions of dollars in business maintain little presence and conduct little economic activity in Luxembourg. One popular address – 5, rue Guillaume Kroll – is home to more than 1,600 companies.

ICIJ journalists also published articles that go into greater depth about the findings in major newspapers, including The Guardian, the Irish Times,  CBC News, and Le Monde.

The “Luxembourg Leaks” are a huge blow to the credibility the European Commission’s new president, Jean-Claude Juncker, who was Luxembourg’s Prime Minister when many of the tax deals were struck.

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Related MNE Tax articles:


Luxembourg defends tax rulings: “The rulings in Luxembourg are compatible with the Luxembourg legislation, compatible with the EU-legislation, and compatible with the OECD-conventions, and any other international conventions,” Minister of Finance, Pierre Gramegna, said November 6, at the Ecofin council in Brussels. See speech.

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Jean-Claude Juncker should resign says Bloomberg: Jean-Claude Juncker, the new president of the European Commission, has a “clear conflict of interest” as head of the body investigating the tax practices he oversaw as Luxembourg’s prime minister, says Bloomberg in a November 9 opinion piece. See, Bloomberg.