Читать книгу Financial Cold War. A View of Sino-US Relations from the Financial Markets онлайн

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Exemption from withholding taxes was just one of many issues that had to be resolved though. Over a period of six months, Warburg executives and their lawyers, Allen & Overy, engaged in extensive negotiations with the Inland Revenue, the Stamp Office, the Bank of England, and the London Stock Exchange.

For a dollar bond issued outside the US, there was no requirement for it to be registered with the SEC. However, an arbitrary choice of the location of registration might have impacted investors from outside that jurisdiction. It was therefore determined that the bonds would be issued in bearer form, which meant that there would be no registered owner, and no records of the identity of the owner or changes in ownership. The bearer nature of Eurobond securities would give rise to the popular stereotype of the ‘Belgian dentist’. In Belgium, interest on domestic bond issues were taxed at source, so the Belgian dentist came to symbolise the affluent European investor who would invest in these issues via an account in a neighbouring country and, given the anonymity of the bearer structure, then evade taxes by failing to report the income to his home tax authority. Investments were often made via banks based in Luxembourg, which would clip the couponsssss1 on behalf of the investor and deposit the income into his account. The briefcase-bearing Belgian dentist, often accompanied by his wife or mistress, could be seen most weekdays riding the morning train between Brussels and Luxembourg City, nicknamed the ‘Coupon Express’. After a substantial lunch and a visit to his bank, he could then be seen returning to Brussels on the evening train.