By MARK COBLEY
THE WALL STREET JOURNAL EUROPE
February 26, 2008
Royal Dutch Shell PLC’s main U.K. pension plan, one of the biggest in the country, is considering a first investment in hedge funds after tax-policy fears were allayed by Revenue & Customs, the U.K.’s central tax authority.
The fund with £13 billion, or about $25 billion, in assets, recently sought clarification from Revenue & Customs.
“Such clearance has only recently been obtained, and the trustees will be looking at whether we make a small investment in hedge funds as part of a portfolio diversification exercise,” Rupert Cox, new chairman of the pension plan’s investment committee, told a members’ meeting last month.
It is rare for U.K. pension plans to put money into hedge funds due to high hedge-fund fees and issues surrounding transparency. Last year, only 31 of 493 plans surveyed by investment consultancy Mercer invested in hedge funds.
In general, a registered pension fund isn’t charged tax on income it receives from investments. But if it undertakes any trading activities, the pension plan is liable for the tax.
“Most activities undertaken by pension schemes are investment rather than trading,” a spokesman for Revenue & Customs said. “Hedge funds are normally established outside the U.K. and undertake a variety of activities, which will usually amount to trading.”
“The tax treatment of an investor depends upon the structure of the hedge fund and whether for tax purposes it is transparent or opaque,” the spokesman explained. “If the particular fund is transparent, the pension scheme is likely to receive trading income, which will be taxable, but if it is opaque, the income is likely to be investment income.
John Hastings, a partner at investment consultants Hymans Robertson, and Debbie Anthony, a tax partner at accountant Deloitte & Touche, said the trustees might have been worried about whether a commitment to hedge funds was regarded as a tax-exempt investment activity.
The Shell plan has named Clive Mather as trustee chairman. A former chairman of Shell U.K. and chief executive of Shell Canada, Mr. Mather will take over May 15.
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.
