How the Dutch helped CBS cheat on its taxes

Onshore-offshore and the IP shell-game.

Cory Doctorow


An icon of a robber running away from a government building holding a loot-sack; the background is the Dutch flag and the robber’s head has been replaced by the CBS ‘eye’ logo. Image: Adrien Coquet/Noun Project (modified) CC BY:

When you think about tax-havens, you probably think about Caribbean “treasure islands,” the ex-colonies whose erstwhile conquerors set them up as dependent financial secrecy jurisdictions whose economies were doomed to be stunted forever.

But in truth, the most harmful tax-havens are “onshore-offshore,” notorious jurisdictions like Delaware, Nevada, and Wyoming, or, in the EU, Malta, Luxembourg, Cyprus, and the Netherlands.

The Dutch are among the most enthusiastic hosts to financial crimes. That’s how Uber cheats on its taxes: It has 50 Dutch shell companies that it launders its money through.

They document the tissue-thin pretenses that Dutch regulators tolerate, like “selling” its IP to a Dutch subsidiary financed with a $16b “loan” from a Singaporean subsidiary, garnering 20 years’ worth of $1b annual tax credits.

Uber may be an aggressive user of the Dutch system, but they’re not the only one. Viacom-CBS evaded a $4b US tax-liability by pretending to license its IP to shell companies in “Barbados, the Bahamas, Luxembourg, the Netherlands, and Britain.”

While this was a global affair, the Netherlands were central to the con, because of its 0.8% tax rate on foreign distribution revenues.

CBS jealously defended the pretense that a series of numbered companies with few (or zero!) employees were actually conducting its licensing and distribution business, firing at least one exec who tried to blow the whistle on the scheme.

The billionaire Redstone family — who controlled the company through most of this activity and whose scion, Shari Redstone, is its current CEO — dispute the careful, well-documented claims in the report, though they offer no evidence to contradict them.