FINANCIAL TIMES: Call for Shell to alter its plan to unify
31 May 2005
By Clay Harris
Royal Dutch/Shell should modify its unification proposals to minimise the potential tax burden on a relatively small group of individual shareholders in the UK, an investment industry leader said yesterday.
Under the scheme due to be considered by shareholders next month, UK holders of Royal Dutch who accept shares in the new unified Royal Dutch Shell will be treated as if they had disposed of their old shares, giving rise to a potential capital gains tax (CGT) liability.
Institutional investors are not affected, meaning the burden will fall on individual holders. Other shareholders, including the majority of UK investors who own Shell Transport & Trading shares, do not face the same liability from the complex plan to unify the Dutch and UK companies.
Angela Knight, chief executive of the Association of Private Client Investment Managers and Stockbrokers, said UK holders of Royal Dutch, the Dutch part of the oil and gas group, should be offered a loan note alternative.
Loan notes, a common instrument in UK takeovers, enable shareholders to spread out their “disposal” and ameliorate CGT exposure. Ms Knight, economic secretary to the Treasury in the last Conservative government, said responses from 16 Apcims member firms showed that at least 1,080 investors, with aggregate Royal Dutch holdings of £80m, were affected.
She expected the total to be twice that, and said the investors involved were, on average, well into their 70s.
Ms Knight said: “Presenting a big tax bill to a group of elderly pensioners is an unacceptable side effect of the restructuring. At the very least, Shell should offer the alternative of loan notes or similar as other companies have done in the past.”
She has spoken to Shell and written to the paymaster general, the minister responsible for the Inland Revenue.
Shell said yesterday: “All Royal Dutch shareholders have the same entitlement to Royal Dutch Shell shares under the offer. All shareholders are being treated equally under the terms of the transaction, which is structured on a pre-tax basis.
It added: “It is not possible to treat everyone equally on a post-tax basis when so many jurisdictions’ tax laws are involved. Under UK law, there are many provisions under which individuals can reduce or eliminate any tax payment upon acceptance of the Royal Dutch offer.”
This website and sisters royaldutchshellplc.com, shellnazihistory.com, royaldutchshell.website, johndonovan.website, and shellnews.net, are owned by John Donovan. There is also a Wikipedia segment.
Royal Dutch Shell conspired directly with Hitler, financed the Nazi Party, was anti-Semitic and sold out its own Dutch Jewish employees to the Nazis. Shell had a close relationship with the Nazis during and after the reign of Sir Henri Deterding, an ardent Nazi, and the founder and decades long leader of the Royal Dutch Shell Group. His burial ceremony, which had all the trappings of a state funeral, was held at his private estate in Mecklenburg, Germany. The spectacle (photographs below) included a funeral procession led by a horse drawn funeral hearse with senior Nazis officials and senior Royal Dutch Shell directors in attendance, Nazi salutes at the graveside, swastika banners on display and wreaths and personal tributes from Adolf Hitler and Reichsmarschall, Hermann Goring. Deterding was an honored associate and supporter of Hitler and a personal friend of Goring.
Deterding was the guest of Hitler during a four day summit meeting at Berchtesgaden. Sir Henri and Hitler both had ambitions on Russian oil fields. Only an honored personal guest would be rewarded with a private four day meeting at Hitler’s mountain top retreat.
IN JULY 2007, MR BILL CAMPBELL (ABOVE, A RETIRED GROUP AUDITOR OF SHELL INTERNATIONAL SENT AN EMAIL TO EVERY UK MP AND MEMBER OF THE HOUSE OF LORDS: 
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A head-cut image of Alfred Donovan (now deceased) appears courtesy of The Wall Street Journal.
