The record company pays the part of the proceeds that goes to the artist as a royalty to the license holder, the private limited company, who then pays it as a royalty to the owner, the public limited company. The Dutch private limited company, in turn, sublicenses the music to a record company that sells the music in Germany and France. The public limited company in Curaçao has the intellectual property rights, and licenses them to the Dutch private limited company. How does a musician get his royalties to Willemstad from, say, Germany or France? It works like this. In addition, the Netherlands does not levy taxes on outgoing interest and royalties, meaning these could be sent to Curaçao tax-free. Furthermore, the Netherlands had a favourable tax treaty with the Antilles, which belonged to the Kingdom, so that money could be sent from the Netherlands to the Antilles without extra taxation. The Netherlands has a tax treaty with almost every country in the world, allowing money to be transferred at favourable rates from abroad to a company based here. This could be circumvented by first sending the money to the Netherlands. As a result, other countries imposed taxes in advance when a legal person channelled money to Curaçao.
In the end, Ulvaeus was acquitted, or so he claimed years later.Ĭuraçao hardly levies any taxes and did not have a tax treaty with virtually any country. But when Ulvaeus returned to live in his native Sweden, things went sideways: the Swedish tax authorities demanded 87 million Swedish kronor (equivalent to about 8.5 million euros) in back taxes and interest. The rule basically means that the British tax authorities ask few questions about these people’s income and its origin. England has a ‘ non-dom tax rule’ that is attractive to wealthy foreigners. This tax dodging structure was not a problem for Ulvaeus, because he lived in London. Those are the main ingredients of the ‘Antilles route’, which was widely exploited until 2006. He had a private limited company set up in the Netherlands and a public limited company in Curaçao, allegedly already in the mid-seventies. It can be dangerous for a superstar who has sold millions of records to tell people where they reside most of the time. ‘In Paris,’ he muttered, but only when he was not residing in London, Athens or elsewhere.
‘Where do you live?’ It seems like a simple question, but Greek synthesiser-virtuoso Vangelis refused to provide a straight answer in 2019 when a Los Angeles Times journalist posed the question.
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