Annex 1: Details of partnerships and companies involved in the tax avoidance scheme
Published 18 January 2019
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Mountstar (PTC) Limited
Corporate trustee of The Cup Trust
Place of registration or jurisdiction
British Virgin Islands
Date established or incorporated
2 Jan 2009
Roles and dates the roles were taken on
Mr Jenner – Director from 2 Jan 2009 to 21 Jan 2010 and from 3 June 2010 to date [footnote 1]
Mr Mehigan – Director from 10 March 2009 onwards
Mr Stones – Director from 26 Jan 2010 to 22 April 2013 [footnote 2]
HNW Tax Advice Partners (HNWTAP)
General partnership that provides tax advice or tax planning for individuals
Place of registration or jurisdiction
English Law
Date established or incorporated
20 Nov 2009
Key personnel and when they took on their roles
Mr Jenner – HNWTAP had two partners until 17 December 2010, Mr Jenner (95%) and HNWPT (5%).
Mr Jenner was a partner from 20 Nov 2009 to 20 Dec 2010. Although the exact ownership changed subsequently, for all material purposes and times in this period, a key beneficiary was Mr Jenner, although he explained this did not necessarily entitle him to income.
On 17 December 2010, HNWP1 became a partner, until May 2013.
In May 2013, HNWP2 became a (the then sole) partner.
HNW Tax Services (HNWTS)
General partnership that provides attorney services for individuals
Place of registration or jurisdiction
English Law
Date established or incorporated
20 Nov 2009
Key personnel and when they took on their roles
Mr Jenner was Partner from 20 Nov 2009 onwards
HNW Partnership Trust (HNWPT)
Trust, which is a partner of HNMTAP and HNWTS
Place of registration or jurisdiction
Not known
Date established or incorporated
Not known
Key personnel and when they took on their roles
Mr Jenner was Trustee until 5 April 2010. Beneficiary at various times.
Mr McCulloch and another became a partner of this trust.
Romangate Ltd
Acted as bare trustee / assets held beneficially for the vendor and The Cup Trust
Place of registration or jurisdiction
UK
Date established or incorporated
14 Nov 2011
Key personnel and when they took on their roles
Mr Jenner was Director from:
- 1 Dec 2008 to 9 Jan 2009
- 21 Jan 2009 to 21 Jan 2010
- 27 Jan 2010 to date
He was Company Secretary from 27 Jan 2010 onwards.
Mr Mehigan was Director from 24 Nov 2008 to 9 Jan 2009 and from 10 Feb 2009 to 10 Feb 2010.
Mr Stones was Director from 27 Jan 2010 to 22 Dec 2010.