history of communication between ef education first and … · 2017. 11. 9. · october 11, 2017...

History of Communication Between EF Education First and

Uppdrag granskning

October 6, 2017 - November 7, 2017

Note: EF Education First would like this document to be published online in its

complete form as Uppdrag granskning has offered. Please also note that EF's response to

Uppdrag granskning's investigation is only complete if it includes the full history of our

communication.

October 6, 2017

Email from Evangeline Frey Kraus (EF Education First) to Joachim Dyfvermark (Uppdrag granskning)

EF Correspondence with Uppdrag granskning Page 1

October 10, 2017

Email from Joachim Dyfvermark (Uppdrag granskning) to Evangeline Frey Kraus (EF Education First)

From: Joachim Dyfvermark [mailto:[email protected]] Sent: Tuesday, October 10, 2017 6:03 PM To: Evangeline Frey Kraus <[email protected]>; Press <[email protected]> Cc: 'Sven Bergman' <[email protected]> Subject: Request Swedish Television Importance: High

Request for interview attached.

****************************************************************** Joachim Dyfvermark reporter / producer Current affairs Uppdrag granskning Swedish Television [email protected] [email protected] Mobile +46706227575 fax +46 8 55 114 228 Skype: dyfvermark Ragvaldsgatan 19c, S-118 52 Stockholm, SWEDEN PGP: www.trojkan.se ******************************************************************


mailto:[email protected]






http://www.trojkan.se/

October 10, 2017

Email attachment from Joachim Dyfvermark (Uppdrag granskning) to Evangeline Frey Kraus (EF Education First)


October 11, 2017


Från: Evangeline Frey Kraus [mailto:[email protected]]

Skickat: den 11 oktober 2017 09:45

Till: Joachim Dyfvermark <[email protected]>

Ämne: RE: Request Swedish Television

Dear Mr. Dyfvermark,

Thank you for your email. As I mentioned to you in my email last week, I am happy to help you get answers to your

questions. I kindly ask you to please send the questions to me in an email.

Best regards,

Evangeline Frey




October 11, 2017


From: Joachim Dyfvermark [mailto:[email protected]]

Sent: Wednesday, October 11, 2017 9:56 AM

To: Evangeline Frey Kraus <[email protected]>

Cc: 'Sven Bergman' <[email protected]>

Subject: SV: Request Swedish Television

Hi Evangeline,

Thank you for your email. The questions differ depending on if we get to interview Bertil Hult or an EF representative.

Best regards

/Joachim





October 11, 2017





Kopia: 'Sven Bergman' <[email protected]>


Dear Joachim,

Thank you for your email. We would be happy to answer your questions in writing. You are welcome to send them

through to me.

Kind regards,

Evangeline





October 11, 2017



Sent: Wednesday, October 11, 2017 3:07 PM


Cc: 'Sven Bergman' <[email protected]>


Thank you for your reply, but we are asking for an interview. With Bertil Hult, or a representative from EF. I will be happy

to send you the topics/questions when we know who to interview.

Best regards

/Joachim





October 11, 2017





Kopia: 'Sven Bergman' <[email protected]>; Martha Doyle <[email protected]>


Dear Joachim,

As you know from your colleagues, a couple of years ago you made an interview with EF’s spokesperson, Martha Doyle,

in Boston. You are certainly welcome to interview her again in Boston. However, she will want to have your main

questions for the interview beforehand so she can speak to the appropriate people to find out the right answers.

Best regards,

Evangeline






October 11, 2017



Sent: Wednesday, October 11, 2017 4:36 PM



Hi Evangeline,

Thank you for the offer, but I will not be in Boston on Tuesday but in Luzern. I am sure there must be someone from the

HQ that can answer questions as well?

/Joachim




October 12, 2017






Dear Joachim,

Since many years EF has no longer had one head office. Instead we have several regional head offices. The reason for

this is that those offices are closer to our markets. Our largest regional head offices with the most resources are in

Boston USA and Shanghai China where we have several thousand employees. Here in Luzern we are only a few hundred.

Joachim, you asked for an interview with a representative from EF and that you would be happy to send us the topics/

questions when you know who to interview. Again, you are very welcome to interview Martha Doyle who works out of

our Boston office and is EF’s only spokesperson. Please send your questions in writing and in good time before the

interview so she can find out the answers.

However, if you do not want to travel to Boston, I am happy to help you by providing written responses to your

questions. Please send them, preferably detailed, and I will try to find out the answers for you.

Best regards,

Evangeline




October 13, 2017



Sent: Friday, October 13, 2017 9:20 AM



Hi,

Thank you for your reply.

I have been doing investigating journalism for 20 years, for the past ten years most of the stories have been about

multinational companies. I have seen the interview with Martha Doyle from 2013, and that is not what we are asking

for.

When investigating EF/Hult´s offshore structure all the threads leads to Luzern, and if Bertil Hult won´t do an interview

we need someone with knowledge about the structure, who can answer follow up questions, like CFO or senior

members from group management.

Best regards

/Joachim




October 13, 2017





Kopia: Martha Doyle <[email protected]>


Dear Joachim,

Thank you for your email. Again, you are welcome to send the questions to Martha Doyle and have an interview with

her after she has received them. Or, you can send the questions to me and I will see to it that you receive a written

answer to them.

Best regards,

Evangeline





October 13, 2017



Sent: Friday, October 13, 2017 2:23 PM



Hi!

I will send you my questions tomorrow (I am traveling today) and I will be in Luzern on Tuesday. If you want to deliver a

written statement then, or provide me with an interview with someone outside the PR department that is up to you. We

are doing television and written statements, or interviews with a press spokesperson is bad for us both.

/Joachim




October 13, 2017





Kopia: Martha Doyle <[email protected]>


Dear Joachim,

Thanks for your reply.

There must be a misunderstanding about Martha Doyle’s role, as Martha Doyle does not work in EF’s PR department,

and has never done so.

Martha started right out of college at EF and started working as Bertil Hult’s assistant some 30 years ago. She remained

his assistant all the years Bertil Hult lived in Boston. After this Martha was promoted to different positions and has since

year 2005 held a number of key executive positions in EF. Martha is today EFs CAO (Chief Administration Officer). Since

Bertil Hult retired there is no one who is more knowledgeable about EF’s different operations than Martha Doyle, and

that is the reason why she is EF’s spokesperson.

However, I look forward to receiving your questions if that is still your preference. It is however not reasonable to

expect me to have answers for you in one day. I would need at least 5 working days to ensure I can gather the

information to your questions from the relevant people. This means I could commit to responding to you by the end of

next week if I receive the questions during this weekend.

Wishing you a nice weekend.

Best regards,

Evangeline





October 14, 2017



Sent: Saturday, October 14, 2017 5:42 PM



Hi Evangeline,

Well, in SVT`s interview from 2013 Martha Doyle says she knew nothing about Signum International SARL and the in-

house trademark invoices. And anyone with a minimum of insight into the offshore structure of HULT/EF would know

about Signum International SARL. She was obviously not trusted with that information.

There are a number of people in EF who have maintained the offshore structure who would be able to answer questions

about the offshore companies in the Hult/EF structure. And to say that you have had 1 day to prepare answers is just not

true. I sent you the first email one week before the time of our arrival on Tuesday, giving you the topic of our questions

– the EF offshore structure.

And here are the topics that I would like to talk about in an interview:

- Internal trademark invoices, transferring money from onshore to offshore- Cash pooling with onshore and offshore companies

Best regards

/Joachim




October 16, 2017



Skickat: den 16 oktober 2017 12:25:53 CEST



Dear Joachim,

Thank you for your email.

Bullying me or coming with incorrect statements will not speed up my work.

It is correct that about one week ago you sent me an email that you are interested in having an interview with Bertil

Hult or someone else at EF. I have repeatedly offered you to have an interview with Martha Doyle or that I will provide

you with written answers to your questions when I get them.

On this past Wednesday, October 11, you wrote to me “I will be happy to send you the topics/questions when we know

who to interview”. Again I repeated that you are welcome to interview Martha Doyle and send the questions

beforehand to her or send the questions to me and I will provide you with written answers.

On this past Friday October 13 you wrote “When investigating EF/Hult’s offshore structure all threads lead to Luzern”

and hours later you sent me a new mail saying “I will send you the questions tomorrow”. I normally don’t work on

weekends as I have two small children to look after.

This morning I have asked all colleagues in Luzern who might have some knowledge about the topics you sent and got

the answer that I have to ask colleagues in our Boston office, which opens at 3pm our time.

I have phoned our Shanghai office and they also referred me to colleagues in Boston or perhaps to colleagues in our

Denver office, our second largest office in the US, but they open even 2 hours later than Boston.

As explained I am happy to help you to obtain written answers to your topics if you don’t want to do an interview with

the person who is responsible for that function, Martha Doyle.

I also want to reiterate that there is not going to be an interview in Luzern, which I have already informed you of several

times. If you travel here for that purpose you will unfortunately be traveling unnecessarily. Responses from me to your

questions will be sent to you via email and as promised no later than on Friday, hopefully already on Wednesday or

Thursday.




October 16, 2017 - CONTINUED


Apart from the topics you identified to me over the weekend, which I read this morning, we note that one area of

interest you have brought up to several current and former EF employees you have been in contact with relates to the

corporate jets used by EF. These are being used in the normal course of business for the EF companies and they are also

used by Bertil Hult and his family privately. In regards to this we can only reconfirm what we told Uppdrag Granskning in

2013 that Bertil Hult, privately with no exemptions, covers 100% of all costs that has to do with his and his family’s

private life. That goes for both direct and indirect costs.

In your email to me you also refer to looking for information about “Hult”. I would assume you are referring to Hult

International Business School. Colleagues here in Luzern cannot provide you with any information nor do they believe

that any EF office can provide you with any information about Hult. Hult is an independent, not for profit, US and UK

charity.

Best regards,

Evangeline


October 16, 2017



Sent: Monday, October 16, 2017 1:42 PM


Subject: RE: Request Swedish Television

Sorry for my short reply, I am in transit. I don't have a hidden agenda. The research we have points to Luzern, and

Martha Doyle did not have any detailed answers during the last interview. I always try to interview people with first

hand information, it is better for both parties I think.

Regarding answers over emails: I am a journalist, I do interviews and ask questions, and follow up questions. Having that

process done over email opens up for second and third party answers. And it is impossible for the audience to grasp the

context of written statements in TV.

That is why I urge you to let me interview some one of the financial directors in Luzern about the issues I have

presented.

We can meet, I will show you the information and the questions I have and you can prepare while we set up the

equipment.

I hope we can work something out.

Best regards

Joachim




October 16, 2017


From: Evangeline Frey Kraus

Sent: Monday, October 16, 2017 5:38 PM

To: 'Joachim Dyfvermark' <[email protected]>

Subject: RE: Request Swedish Television

Dear Joachim,

As promised, I have now been able to talk to my colleagues in Boston and can confirm that I will be able to answer your

questions in writing as promised no later than on Friday.

In terms of this week – you do not seem to acknowledge that I have several times informed you that there will be no

interview in Luzern.

Please respect that we have offered you a live interview which you say you want to do, with one of EFs most senior

employees with the knowledge of EFs operations over 30 years. If you think it is too far, or too costly, to travel to

Boston, we have given you the other alternative; that I will provide you written answers to questions you send me. You

can of course take pictures outside our beautiful Luzern office but you are not scheduled for a meeting with me or

anyone else in Luzern.

Martha Doyle has a very thorough level of knowledge about the worldwide EF operations but of course she as an

individual person does not sit on detailed answers for all questions you could come up with. That is why we also for an

interview would ask for questions in advance – to help facilitate that process. EF has over 40,000 people involved in our

operations and that is much too big an organization for any single person to have answers to all questions.

EF’s policy is to be fully transparent toward the authorities around the world where we operate. Other than that we

keep a low profile and we are proud of the fact that several million students want to participate in our programs every

year. Being a very successful company, EF nevertheless faces competition in some of our major markets so please

understand that EF is reluctant in giving out some company information to the media. Regardless of this we have tried

to accommodate your wishes and offered you an interview or alternatively to provide answers in written form.

I would also like to again correct your statement about Luzern “being EF’s head office” so you do not publicly go out with

incorrect information. You have been informed that we do not have one head office but several regional head offices.

Best regards,

Evangeline



October 19, 2017





Ämne: FW: Request Swedish Television

Dear Joachim,

I heard from my colleagues that you chose to visit our Lucerne office the day before yesterday, regardless of the

communication we have had about you not having a meeting appointment. I was working with our, soon to be, new

Swiss head office in central Zurich where we will host the majority of our six hundred Swiss staff when

the building is ready next year.

I understand from my colleagues that you are particularly interested in the following topics.

CORPORATE AIRPLANE

I heard from my colleagues that you want to know even more about our airplane then the information I have already provided to you.

"The airplane are being used in the normal course of business for the EF companies and they are also used by Bertil Hult and his family privately. In regards to this we can only reconfirm what we told Uppdrag Granskning in 2013 that Bertil Hult, privately with no exception, covers 100% of all costs that has to do with his and his family’s private life. That goes for both direct and indirect costs."

Our airplane are built in France, outfitted in the US and imported into Denmark. They are registered in Denmark and "fly under Danish flag". The Danish management company make the "heavy" services on the airplane. When Bertil Hult lived in Sweden in the 90s we had a hangar build at Stockholm Bromma airport where still all the "light" services on our airplane are performed.

WEDDING PRESENTS

When several of Lisbeth and Bertil Hult’s friends’ children have grown up and got married, Lisbeth and Bertil have given

them, as a wedding present, a flight to their sailboat and a stay onboard the sailboat for a week or two. I do not

understand why you are so interested in this topic but all I can understand from the couples I have met is that they have

been extremely happy with their stay onboard the sailboat.

MALTA

I understand that you or one of your colleagues went to Malta this week, where you apparently went to our registered

office to see our corporate secretary instead of visiting our business office. Our registered offices addresses around the

world are normally the office address of the law firm in that country, which incorporated the company for us. They are

not in a position to give any information about our activities in the country.






I hope you still had the opportunity to see our school and other activity centers when you were there. Malta is a location

where we have both year-round and summer schools for our language abroad operations. Over the years we have had

over a hundred thousand students in Malta. We have approximately 60 employees year round and many part

time teachers.

INTERNATIONAL TRADEMARK

There are no, and have never been any, license payments made from any Swedish EF company.

For other countries, anyone benefitting from the use of EF’s intellectual property including trademarks is charged with a

license fee. This is the case for both EF entities and external parties being granted those rights. The price for the right to

use those assets is the same whether you are an EF affiliated company or a totally external third party. We have over

one hundred external parties paying for the right to use these assets.

CASH POOLING

EF is a worldwide group with entities in more than 50 countries. To be able to manage the flows between these entities

in an efficient way the group has organized some of its financial flows via cash pooling and financial clearing. The main

geographies involved in these agreements are US, UK, Switzerland and China as that reflects the biggest regions for EF

but other jurisdictions are also represented given the breadth of our operations. Cash pooling, is simply a way of

managing the flows under the agreement, normally done under the coordination of our key bank in the respective

country. In all countries where EF use cash pooling and financial clearing such is operated in full compliance with the

applicable tax legislation and equally important with its overall purpose.

BULLYING

Joachim, we have given you the opportunity to interview one of our senior executives or to send your questions to me

and I will find out the answers and write back to you.

After yesterday it is obvious that you do not read what I write to you, or you totally ignore it. I also feel that you are

bullying me, which I wrote to you earlier. Therefore, I do not want to continue our correspondence.

Several, both former and present colleagues, have contacted me this past week, where many of them feel that you are

harassing them and make them feel sick.

The day before yesterday, our receptionist in our office felt extremely uncomfortable when you stormed in with your

camera man.




We just do not believe you, when you say that you do not have any hidden agenda. You say that all you want to know is

about international trademark and cash pooling. Then it would be sufficient with the means we have provided you, an

interview with Martha Doyle or written answers to your questions.

I have, as promised, answered the questions as well as we could in the short period of time that you gave us. We offered

you an interview with one of our senior executives which you were not interested in, you don't respect what I write to

you and many of our staff, former and present, feel that you are threatening and bullying them. The consequence of

your behavior is that we don’t think it is meaningful to continue any communication with you.

Best regards,

Evangeline


October 19, 2017



October 21, 2017


From: "Joachim Dyfvermark" <[email protected]>

Date: 21 October 2017 at 15:47:10 CEST

To: "'Evangeline Frey Kraus'" <[email protected]>

Cc: "'Nils Hanson'" <[email protected]>, "'Sven Bergman'" <[email protected]>


Evangeline,

Sorry for my late reply, I am just back in Sweden after an interesting journey.

Let me first pinpoint an important research-issue. Could you please refer this part to someone who can answer (since

you no longer want to reply to me).

You write:

Our airplane are built in France, outfitted in the US and imported into Denmark. They are registered in Denmark and "fly

under Danish flag". The Danish management company make the "heavy" services on the airplane. When Bertil Hult lived

in Sweden in the 90s we had a hangar build at Stockholm Bromma airport where still all the "light" services on our

airplane are performed.

Question: What is the name of the Danish company/ies importing the two “corporate flights”? Since when does Falcon

2000 (tail nr VP-BRA) and Falcon 7x (tail nr VP-BEH) fly under Danish flag? VP-B are Bermuda call signs

(http://www.logisticair.com/aircraftcallsignidentifier.html).

***

Regarding your accusations.

EF is language company, and one would think that representatives from that group be more careful with words.

“Bullying” is not just a strong word, but implies that there is an intent to damage the person exposed. I have been in this

business for over 20 years, and have experienced many international companies attempts to attack me, but this was a

new strategy.

I have not asked to have contact with you, I have always asked for Betil Hult or someone in the management team who

can answer questions about Bertil Hult's offshore companies. You have delivered the EF's positions, and I have explained

why we need a real interview with Bertil Hult or others with insight and knowledge about the structure we are

investigating. I clearly flagged that we were going to Lucerne, EF were prepared and we were met by a photographer

who filmed our visit in the reception. Finally after the interview with Fredrik Manse, I apologized to the reception staff,

after which they replied: "No worries, have a good day."






http://www.logisticair.com/aircraftcallsignidentifier.html



Your statements are so absurd that I have to conclude that it is part of the EF`s strategy to attack the free press. We will

continue to ask questions about the EF, we will continue to investigate Bertil Hult and he/EF can freely choose how to

respond to our questions. That is the basis of a democracy, there is no obligation to answer to questions from

journalists, and there is - above all - no obligation to comply with a multinational company's demands on journalists how

to conduct their investigations.

Hereby we end our dialogue, and I therefore wish to be referred to someone else who represents Bertil Hult and the EF.

/Joachim


October 24, 2017

Email from Joachim Dyfvermark (Uppdrag granskning) to Martha H. Doyle (EF Education First)


Sent: Tuesday, October 24, 2017 7:40 PM

To: Martha Doyle <[email protected]>

Cc: Evangeline Frey Kraus <[email protected]>; 'Nils Hanson' <[email protected]>; 'Sven Bergman'

<[email protected]>

Subject: Questions Swedish Television

Importance: High

Dear Martha Doyle,

My name is Joachim Dyfvermark, producer at Swedish Television and team leader for an international group of

investigative reporters who have done research about Mr Bertil Hult and EF during the last couple of months. I have

been referred to you by the EF staff in Luzern, and I tried to reach you today over the phone to introduce myself and let

you know that this email is coming. But the staff in Boston could not find you.

Attached are the questions we have at this point. We would very much appreciate if we could have your reply no later

than October 31, 6 pm (CET) in order to make possible corrections before we publish.

As I have said before, many times as you might be informed about, we would like to interview Mr Bertil Hult. If that is

not possible we kindly ask for an interview with you, over phone or Skype since our North American correspondent is on

a mission.

Looking forward talking to you.

Best regards

/Joachim Dyfvermark











Letter to Mr. Bertil Hult

Table of Contents:

Table of Contents: 1 Background 2 Bertil Hult´s Jets and VAT 3 Pilot tax evasion 7 Bertil Hult´s Yachts 7 Moving assets from onshore to offshore entities 8 Offshore financing of private real estate 9 Comments from experts 11

October 24, 2017 Email attachment from Joachim Dyfvermark (Uppdrag granskning) to Martha H. Doyle (EF Education First)


Background

Uppdrag granskning, Swedish Television, have access to a large number of internal documents from

Bertil Hult´s offshore companies. In recent months we have investigated the EF's operational

activities onshore, but mainly the offshore operations, including the following companies:

Alpha Efekta LTD

Black, Blue, Brown, Polar Bear Ltd (new and old company with the same name)

Efekta Bridge, Spires, Reef, Rose Ltd

Englishtown ltd (Bermuda)

Exelenz holding ltd

Go Ahead International

Hult International Business school ltd (Bermuda)

Ivy Education Ltd.

Longjump Ltd.

Oldtown Ltd.

Pilatus Ltd

Private S.Y. Erica XII Ltd. (Bermuda and Malta)

REEF Ltd. (Bermuda)

Rushmore Ltd.

Signum International Ltd. (Bermuda)

Signum lnternational S.a.r.l

Volo Ltd

We trace tax exemption for the Hult companies in Bermuda all the way back to year 2000:



In internal documents we find reasons to remain in Bermuda because of tax reasons.

As a result of our investigation we have identified a number of different versions of avoiding tax. We

will divide the questions and the conclusions based on topics below.

Bertil Hult´s Jets and VAT

Background:

Bertil Hult owns (through a lease-buy setup with offshore companies) two private/business jets. One

Falcon 2000 and one Falcon 7X.

Dassault Falcon 2000 LX

Serial nr:133

Registered owner: Rushmore Ltd.

Call sign: VP-BRA

Dassault Falcon 7X

Serial nr: 21

Registered owner: Volo Ltd.

Call sign (until 2017-10-16): VP-BEH

Chain of ownership

Bertil Hult is the UBO of Exelenz Holding (previous names: Go Ahead vacations and Alpha Charter

Ltd).

From Exelenz Holdings internal documents:

***



Bertil Hult is signing the lease/buy agreement with Dassault Falcon Jet Corp:

First page page, and signature from lease agreement:

/…/



Two initial installments were made (total of USD 3.813.000), and after delivery monthly lease

payments.

Private use:

Uppdrag granskning, Swedish Television, have tracked the airplanes movement since January 2009

(multiple sources: official documents, human sources, plane spotters, and electronic tracking

systems) and the conclusion is that Bertil Hult, his family and friends are using the aircraft for

personal use – outside the flights connected to EF`s business.

In an email from Evangeline Frey Kraus (2017-10-19) it says:

"The airplane are being used in the normal course of business for the EF companies and they are also

used by Bertil Hult and his family privately. In regards to this we can only reconfirm what we told

Uppdrag Granskning in 2013 that Bertil Hult, privately with no exception, covers 100% of all costs

that has to do with his and his family’s private life. That goes for both direct and indirect costs."

In the internal documents we have from the offshore companies in question we see no payments

from Bertil Hult. All payments comes from EF related corporations:

From board Exelenz Holdings board minutes:

VAT refund

After investigating Hult´s offshore companies we see no evidence of Bertil Hult/EF reducing VAT

refunds, or repaying already reduced VAT because of private use.



If you have additional information please send us this as soon as possible, with documents that

reinforce your statements.

a) Bertil Hult's private compensation to the offshore companies for private use. Compensation level

and payment of VAT for private use of the aircraft.

b) Reduction of VAT refund when entering EU/Switzerland.

Summary:

1) Bertil Hult has set up a chain of companies that were designed to give the impression of a

100 % jet leasing business, and therefore entitled to VAT refunds for the purchase of the jets.

2) All of the companies in the chain were – in the end - owned by the same individual, Bertil

Hult.

3) The companies has no offices, no phone lines on Bermuda and no website. The structures

contained only one aircraft, and served only one customer.

4) Hult appears to have created a tax avoidance scheme which resulted in the creation of

artificial leasing businesses, rather than a genuine leasing businesses.

5) Had these jets been imported via the EU or Switzerland VAT would have been payable up

front. It could then have been reclaimed in subsequent tax returns, but only in proportion to

the amount of business versus leisure use of the jets.

6) VAT should not be reclaimed at 100% if goods are put to some non-business use. With jets,

personal or leisure flights, for holidays or family visits, are taxable.

7) We believe these structures were also used to avoid the VAT on the lease payments that

would have been due on leisure flights. Under use and enjoyment rules, European countries

are entitled to require VAT payments on leisure flights that take place in their jurisdictions.

8) However, the Bermuda companies did not add VAT to their leasing invoices, because the

ultimate jet chartering companies were offshore and outwith the scope of European VAT.

If you dispute any of the factual matters, please set these out. It would be helpful in that regard if

you would address each point separately and explain which statements or facts you dispute and why.

Please offer the correct information.

We would welcome your responses and any comments and corrections or clarifications you wish to

make, and would ask that you respond by 6 pm (CET) on Tuesday October 31, 2017.



theresahughes

Inserted Text

Pilot tax evasion

Summary

9) The two jet planes used by Bertil Hult, his family & friends are flown by Swedish pilots

residing in Switzerland. According to several sources, with insight in the terms of the

employment of the pilots, it was a requirement by Bertil Hult that they should reside in

Switzerland to avoid tax, even though they really lived in Sweden.

Seven pilots live at the same address, Morgartenstrasse 3 in Luzern, divided into two

apartments.



Bertil Hult´s Yachts

Bertil Hult, his friends and family have had access to two yachts, Erica XI and Erica XII. According to

the internal offshore documents we have access to, both of the yachts were bought, owned and

operated by offshore companies.

Erica XII

Previous owner:

PRIVATE S.Y. ERICA XII LTD (Bermuda)

Present owner:

PRIVATE S.Y. ERICA XII LIMITED

Malta org. nr C 72161

114 The Strand

According the internal offshore documents we have, the company was founded in September 2015,

it´s owned by Black Bear Ltd on Bermuda. Black Bear is owned by Bertil Hult (all 12000 shares since

March 11, 2005).

When Uppdrag granskning last investigated Bertil Hult, in 2013, representatives from EF claimed that

Bertil Hult payed for private use of yachts.

Summary:



10) When analyzing the financial statements and board minutes of the companies above we

don´t see that Mr Hult have paid anything for his private use of the yacht.

11) We don’t see any VAT being paid for private use of the vessel.

12) Neither can we find any reduction or repayments of VAT-refunds made after the acquisition

in 2009.



Moving assets from onshore to offshore entities

Internal trademark invoicing

Some of the offshore companies in Bertil Hult´s structure are trademark owners (Signum

lnternational S.a.r.l, Englishtown ltd and Ivy Education Ltd for example). We see in the internal

documents that the offshore structure invoice the operational companies for the use of trademarks,

even though they are within the same group, owned by the same family. We see agreements were

the offshore company claims:

Signum lnternational S.a.r.l alone had receivables on 160.962.386 for the year 2016 and USD

246.451.511 for 2015 to other EF entities.

International Services Agreement

We see service agreement with related parties, covering “centralized support services, knowhow and

infrastructure which the group uses for its operation. The remuneration is set as a percentage of the

gross revenue received by the related party”.

We see examples of service agreements invoicing onshore companies more than 8 % of net sales

value.

Other internal payments going from onshore to offshore

We also see “Cost Sharing Agreements” and “Fee payments” going from onshore to offshore

companies



Reducing tax onshore

By analyzing several of the companies in the operational onshore structure we see high turnover, low

profit and low tax. Just as we saw in the investigation 2013.

EF/Hult commented the 2013 investigation saying that Uppdrag granskning looked at the wrong

companies looking for profit and normal tax payments, but EF/Hult did not pinpoint which

companies they referred to.

Money ending up in Bertil Hult´s pocket

We see examples of money flow, from EF´s operational onshore companies in high tax countries to

Bertil Hult through companies in tax havens.

Example:

Signum lnternational S.a.r.l creates costs in onshore companies, and makes a profit in Lumxembourg.

Dividends goes to the owner Blue Bear ltd on Malta. And Blue Bear ltd channels dividends to the UBO

Bertil Hult. With low or no tax on the dividends paid to him from Malta, USD 35.000.000 for the last

two years.

Summary

13) Bertil Hult has created a system where offshore companies are creating costs in the onshore

operational part of EF, lowering the profit and tax in high tax countries.

14) The system is using internal invoicing for Trademarks, Service agreements, Cost sharing

agreements and Fee Payments.

15) Some of the assets are going from onshore to offshore to Bertil Hult.



Offshore financing of private real estate

According to international documents from Bertil Hult´s offshore companies assets obtained in the

offshore structure are being used for acquisition of real estate used privately by Bertil Hult´s family.

Example:



Go Ahead vacation (later Exelenz Holding) buys real estate in London, 20 Painters Yard, 10-14 Old

Church Road. The payment is done through a loan from Brown Bear Ltd. of £ 4,036,000.

The flat used by Bertil Hult son and coming wife:

The flat is refurbished by interior designers Sigmar 263 Kings Road, paid by the offshore company.

Summary

16) Bertil Hult´s offshore company pays for private use of real estate





Comments from experts

Uppdrag granskning have shown our research and our conclusions to tax experts. These are some of

the comments:

17)

The jetplane offshore structure:

- It is not unusual to do like this, you place assets offshore in tax havens and then create a

lease situation. It affects the VAT refunds, and by placing the offshore structure in Bermuda

you also avoid transparency.

18)

Moving assets from onshore to offshore:

- This setup is typical tax planning. With different methods you transfer money from high tax

regimes to tax havens.



Your answers will be shared with other journalists and media outlets cooperating in this investigation.

We kindly ask you to reply on email, or in a recorded interview.

/Joachim Dyfvermark

****************************************************************** Joachim Dyfvermark reporter / producer Current affairs Uppdrag granskning Swedish Television [email protected] [email protected] Mobile +46706227575 Skype: dyfvermark Ragvaldsgatan 19c, S-118 52 Stockholm, SWEDEN PGP: www.trojkan.se ******************************************************************





October 25, 2017

Email from Martha H. Doyle (EF Education First) to Joachim Dyfvermark (Uppdrag granskning)

Från: Martha Doyle [mailto:[email protected]]



Kopia: Evangeline Frey Kraus <[email protected]>; 'Nils Hanson' <[email protected]>; 'Sven Bergman'

<[email protected]>

Ämne: RE: Questions Swedish Television

Dear Joachim,

I am writing to confirm that I have received your email dated Tuesday, October 24th. I am happy to answer your

questions by the deadline you have provided. However, after our initial review, it appears that the majority of your

information is inaccurate and speculative. It seems you are attempting to string together random pieces of information

in order to form a broader narrative.

Regardless of what information you have and how you received it, we will approach this as we have done for each of

Uppdrag granskning’s past inquiries, which is in a transparent and cooperative manner.

I will be back in touch with you before your deadline on October 31st.

Best regards,

Martha

Martha H. Doyle

Chief Administrative Officer

EF Education FirstTwo Education CircleCambridge, MA 02141 USATel: +1 617 619 1000

EF proudly supports the Olympic GamesSeoul 1988 | Beijing 2008 | Sochi 2014 | Rio 2016 | PyeongChang 2018 | Tokyo 2020







October 25, 2017



Date: October 25, 2017 at 6:56:08 PM EDT

To: "'Martha Doyle'" <[email protected]>


Subject: SV: Questions Swedish Television

Dear Martha,


Looking forward talking to you, we have a lot to talk about. Are you using Skype or should we do it over the phone?

Best regards

/Joachim






October 30, 2017


Från: Martha Doyle [mailto:[email protected]]



Kopia: 'Nils Hanson' <[email protected]>; 'Sven Bergman' <[email protected]>; Evangeline Frey Kraus

<[email protected]>

Ämne: EF Response to Uppdrag granskning

Dear Joachim:

Attached please find EF’s response to Uppdrag granskning. Please confirm your receipt of the document.

Best regards,

Martha

Martha H. Doyle

Chief Administrative Officer









October 30, 2017

Mr. Joachim Dyfvermark Uppdrag granskning Swedish Television Ragvaldsgatan 19c, S-118 52 Stockholm, SWEDEN Email: [email protected]


As you may remember from my last interview with Uppdrag granskning a few years ago, I have worked for EF for almost 30 years. I started as Bertil Hult’s assistant and I am now a member of EF’s top management board. I sit in Boston next to our CEO, and I am familiar with EF’s global structure and operations.

Please note our comments in red below. I am sending this ahead of your deadline because I am traveling over the next several days.

Over the past two weeks, we have answered every question you have asked us, many of which are similar to the ones you asked as about four years ago. However, this exercise has been quite time-consuming; consequently, we will not be able to answer any further questions for this show.

If you ever decide to make a fourth show about EF in the future, you now know who to contact.

We trust that SVT will not build a story based on speculations and material that is incomplete or incorrect.

Best regards,

Martha H. Doyle Chief Administrative Officer EF Education First Two Education Circle Cambridge, MA 02141

CC: Nils Hanson, SVT Sven Bergman, SVT Evangeline Frey Kraus, EF Education First

October 30, 2017 Email attachment from Martha H. Doyle (EF Education First) to Joachim Dyfvermark (Uppdrag granskning)



EF Education First’s Response to Uppdrag granskning

General Comments:

EF Education First (EF) was started with 5,000 Swedish kronor, and these 5,000 kronor are still at work today. There has never been any additional capital injected into EF.

When Bertil Hult founded EF, he had one employee. He eventually hired a second employee, and then a third after one year of doing business. Today, EF has more than 46,500 employees and teachers involved in 53 countries, and millions of students participate in EF programs every year.

This growth cannot occur without a significant amount of time, travel and effort. Since he started EF, Bertil Hult has worked virtually every day, from early morning to late at night, and his sons share the same work ethic.

Even though Bertil Hult is now semi-retired, he is working equally intensive with our real estate investments all over the world.

To imply that Bertil has been flying around the world on vacation, for the last 20 years, is not only disrespectful to these achievements, but it is also utterly unrealistic.

As you know, EF is a private company, 100 percent owned by Bertil Hult and his family. We regularly disclose information to accreditors, tax authorities and other public entities as required in all the locations where we do business. Our worldwide structure reflects the activities which take place in the various countries where we are present, and the structure is not set up to “avoid tax” as you speculate.

The material to which you have gained access does not, in any way, support the idea that we have functions in Bermuda for reasons of tax avoidance. The one line you reference about the Board being responsible for its company’s tax residency has nothing to do with tax planning. It is part of the duties of the Board in all jurisdictions to have control and responsibility for the tax residency of the entity they oversee.



Statements listed under Summary related to Bertil Hult’s Jets and VAT:

General Information about EF’s Corporate Aircraft:

Our present aircraft are manufactured by Dassault in France, outfitted in the US, imported to Denmark, and operate under an AOC. We pay VAT or the "high fuel price" on all private flights where appropriate.

All our previous aircraft were manufactured by Dassault in France, outfitted in France, the US or Switzerland, made their maiden flights to London, imported to England for EU VAT purposes, and operated under a Bermuda-registered NCC. They were all owned by Dassault and leased to us. After the leases expired, we had the option to either return them to Dassault or to buy them. They have so far all been returned to Dassault.

We think that you may not have the full understanding of the difference between an AOC (Air Operator Certificate) and a NCC (Non Commercial Complex). Flying under a NCC is not common in Sweden; it is more expensive because the aircraft are subject to EU VAT, and in addition, you pay VAT or the “high fuel price” both for business and private flights. However, flying under a NCC gives you significantly more flexibility than flying under an AOC.

1) Bertil Hult has set up a chain of companies that were designed to give the impression of a 100% jet leasing business, and therefore entitled to VAT refunds for the purchase of the jets.

This is wrong: They were leased from Dassault and the structure does not give entitlement to VAT refunds.

2) All of the companies in the chain were – in the end - owned by the same individual, BertilHult.

The aircraft were leased from Dassault and owned by Dassault.

3) The companies has no offices, no phone lines on Bermuda and no website. The structurescontained only one aircraft, and served only one customer.

This is wrong: 1. The companies have local employees and also both a registered office and a business

office in Bermuda (of course they have phone lines).2. The aircraft serves several EF companies with charter services as well as Bertil Hult

privately.



4) Hult appears to have created a tax avoidance scheme which resulted in the creation ofartificial leasing businesses, rather than a genuine leasing businesses.

This is wrong: There is no tax advantage by leasing the aircraft. There is no artificial leasing. They were genuinely leased from Dassault.

5) Had these jets been imported via the EU or Switzerland VAT would have been payable upfront. It could then have been reclaimed in subsequent tax returns, but only in proportion tothe amount of business versus leisure use of the jets.

This is wrong: 1. The aircraft were imported into the EU and subject to VAT there.2. VAT is paid in the EU on operational costs or the “high fuel price” regardless of

whether the flight is for business or private use.

6) VAT should not be reclaimed at 100% if goods are put to some non-business use. With jets,personal or leisure flights, for holidays or family visits, are taxable.

This is wrong: We reclaim zero VAT.

7) We believe these structures were also used to avoid the VAT on the lease payments thatwould have been due on leisure flights. Under use and enjoyment rules, European countriesare entitled to require VAT payments on leisure flights that take place in their jurisdictions.

This is wrong: The aircraft were imported into the EU. VAT or the "high fuel price" was paid on operational expenses on all flights regardless of whether the flight was for business or private use. VAT was not reclaimed.

8) However, the Bermuda companies did not add VAT to their leasing invoices, because theultimate jet chartering companies were offshore and outwith the scope of European VAT.

This is wrong: 1. The aircraft were imported into the EU and are not outside of the scope of the

European VAT system.2. The “ultimate jet charting companies” were not offshore.



Statements listed under Summary related to Pilot tax evasion:

9) The two jet planes used by Bertil Hult, his family & friends are flown by Swedish pilots residingin Switzerland. According to several sources, with insight in the terms of the employment ofthe pilots, it was a requirement by Bertil Hult that they should reside in Switzerland to avoidtax, even though they really lived in Sweden.

These statements are factually incorrect on several accounts:

1. The aircraft are primarily used for business, not as stated above in the question.

2. The aircraft are flown by Swedish pilots who reside in both Sweden and Switzerland.

3. Your sources are wrong. Each employment contract with a pilot employed inSwitzerland clearly states that the employee has his/her home base and tax residencein Switzerland. It’s the employee’s responsibility to confirm that this is correct. Thecontract states that the company is obliged to pay Swiss social fees and income taxeson the employee’s salary. All our Swiss-based pilots have provided us with residencecertificates from the Swiss Authorities and all our correspondence is mailed to theirSwiss home address.

4. Additionally, all Swedish pilots employed in Switzerland have been informed bothverbally and in writing that they need to live in Switzerland with their familiesor obey the Swedish "6 manaders regeln” if they shall have a tax residence inSwitzerland.

5. As we do with all of our nearly 47,000 employees and teachers around the world, EFexpects everyone to abide by the law and fulfill their tax obligations wherever theymay live.

Further Background:

The background for having Swedish pilots working for EF in Switzerland is the following: EF initially had pilots on Swedish payroll. During this time, we also decided to have a hangar in Sweden and we employed Swedish flight attendants. In 2002 and 2003, we were consolidating several functions to different EF offices around the world. Consequently, some Swedish EF employees were offered to move to Switzerland. The same offer was made to the pilots. The pilots were asked if they were interested in this move and they all said yes. All additional pilots who are working or have worked for us in Switzerland have applied for a job in Switzerland.

We believe it is important to have pilots and flight attendants, regardless of where they chose to live, with the same mother tongue. This is for security reasons, in case there is a stressful situation



while flying. Since we had started with Swedish pilots, this had the consequence of us continuing to recruit Swedish pilots who speak Swedish as their native language.

Seven pilots live at the same address, Morgartenstrasse 3 in Luzern, divided into two apartments.

We cannot comment on specific addresses as this is personal information (you would need to ask the pilots directly).



Statements listed under Summary related to Bertil Hult’s Yachts:

10) When analyzing the financial statements and board minutes of the companies above we don’tsee that Mr Hult have paid anything for his private use of the yacht

This is wrong: We do not know what information you have seen. However, as we have communicated twice before, we can confirm that Bertil Hult covers all costs related to private use of Erica XI and XII.

11) we do not see any VAT being paid for private use of the vessel.

This is wrong: EU VAT has been paid for the vessel.

12) Neither can we find any reduction or repayments of VAT-refunds made after the acquisitionin 2009.

We do not understand the question. The vessel was imported to the EU and EU VAT was paid.



Statements listed under Summary related to moving assets from onshore to offshore entities:

13) Bertil Hult has created a system where offshore companies are creating costs in the onshoreoperational part of EF, lowering the profit and tax in high tax countries.

This is wrong: All taxes are paid in all of our countries of operation based on the activities, functions and risks taking place in each location.

14) The system is using invoicing for Trademarks, Service Agreements, Cost sharing agreementsand Fee Payments

This is wrong: Uppdrag granskning has already been provided information on some of these incorrect claims.

All transactions taking place between EF entities are based on third-party equivalent comparables.

I would like to repeat some of the information you have already received in relation to trademarks:

There are no license payments made from any Swedish EF company nor have there ever been.

For other countries, anyone benefitting from the use of EF’s intellectual property, including trademarks, is charged with a license fee. This is the case for both EF entities and external parties being granted those rights. The price for the right to use those assets is the same whether you are an EF-affiliated company or a totally external third party. For example, we have over one hundred external parties paying for the right to use these assets.

Other service agreements, cost sharing agreements, etc. are in place when services are provided from one country to another. Not having these costs taken by the correct entity benefitting from the services would be unlawful.

15) Some of the assets are going from onshore to offshore to Bertil Hult

This is wrong: There are no assets being transferred to Bertil Hult in this manner. As in any company where you are a shareholder, the owners receive dividends based on the surplus the business is generating.



Statements listed under Summary related to Offshore financing of private real estate:

16) Bertil Hult’s offshore company pays for private use of real estate

This is wrong: 1. EF companies do not hold real estate in the UK for private use for any of the members

of the Hult family.

2. EF has several UK real estate assets held by entities in Bermuda, as it is common thatUK commercial real estate is held by non-UK entities. In most of these cases, theBermuda entity would then be what is referred to as a non-resident landlord (NRL).As such, the Bermuda company still needs to file annual tax returns in theUK. Therefore, there is no corporate tax income benefit for any of these companiesby being located in Bermuda instead of the UK.

3. During a short period, a London apartment was also owned by an EF company inBermuda. Neither EF nor the Hult family gained any tax advantages as a result of this.The apartment was used by Alexander Hult and other executives travelling to London.Alexander Hult was at that time a manager in the EF group and lived in Switzerlandbefore he moved to Boston, USA.



Statements under Comments from experts:

We would like to note that it is not possible for an expert to comment when they do not have the real facts.

17) The jetplane offshore structure:- it is not unusual to do like this, you place assets offshore in taxhavens and then create a

lease situation. It affects the VAT refunds, and by placing the offshore structure inBermuda you also avoid transparency.

This is not relevant for our situation. As outlined above, your speculations related to our corporate jets are factually incorrect.

18) Moving assets from onshore to offshore:- This set-up is typical tax planning. With different methods you transfer money from high

tax regimes to tax havens.

As outlined above, all transactions taking place between EF entities are based on actual business needs and not set up for tax planning purposes.



October 30, 2017



Date: October 30, 2017 at 6:10:36 PM EDT


Cc: "'Nils Hanson'" <[email protected]>, "'Sven Bergman'" <[email protected]>, "'Evangeline Frey Kraus'"

<[email protected]>

Subject: SV: EF Response to Uppdrag granskning

Dear Martha,

Thank you for your reply. We will read you notes carefully and make changes in our research if necessary.

One initial remark, we were promised an interview with you, several times. Is that off?

And second, does your statement today mean that EF/Hult won´t be answering any follow up research questions on

email? How strange is that? I thought you would be keen on getting things right.

I surely hope we get to talk soon.

Best regards

/Joachim Dyfvermark







November 1, 2017


From: Martha Doyle <[email protected]>

Date: November 1, 2017 at 11:27:30 AM EDT

To: "[email protected]" <[email protected]>

Cc: Evangeline Frey Kraus <[email protected]>, "[email protected]" <[email protected]>, "[email protected]"

<[email protected]>

Subject: EF Response to Uppdrag granskning

Dear Joachim,

I am traveling but attached please find EF's response to your email dated October 30, 2017.

Best regards,

Martha

Sent from my iPhone










November 1, 2017




You indicated a hard deadline of October 31 at 6 p.m. CET for all answers to your questions. I spent a considerable amount of time—including all weekend—researching leasing contracts, employment contracts and correspondence, and talking to our finance and legal departments in order to get you clear and accurate answers to every single question ahead of your deadline.

Now it seems like there is no sense of urgency. Of course we want you to report an accurate story, but before we even think about putting more time into this, we need to know when you plan to air your show and what your actual deadline is.

We continue to trust that SVT will not build a story based on speculations and material that is

incomplete or incorrect.

Regards,

Martha H. Doyle Chief Administrative Officer EF Education First Two Education Circle Cambridge, MA 02141, USA


November 1, 2017 Email attachment from Martha H. Doyle (EF Education First) to Joachim Dyfvermark (Uppdrag granskning)



November 1, 2017



Date: November 1, 2017 at 2:32:25 PM EDT



Subject: SV: EF Response to Uppdrag granskning

Hi Martha,

Thanks for your reply.

The deadline in our first letter was set so that we would have time to analyze your reply. In some parts it was easy, in

others not.

In order to be factual correct, and that is the most important thing for us, we kindly ask you to develop the chain of

operation regarding VP-BEH (before it was for sale August 2017).

Background:

Dassault Falcon signs a lease agreement with GO AHEAD VACATIONS LTD, and in 29 September 2006 Volo Ltd was

assigned the lease agreement with Dassault Falcon.

1) You write that the plane was imported into EU through Denmark – by which company and when?

2) You write that you operate under an AOC, what company is the AOC holder?

3) You write that the charting company is based onshore – which company is that, registered where?

Regarding time for interview (over the phone) we have until Saturday. The reportage will be delivered Sunday, and aired

Wednesday. As I stated above we are keen to be correct, and we are keen to have your comments in the reportage (and

in order to make that happen we will have to do this before Sunday).

The sooner we can have your reply on the questions above, the sooner we can inform you about what we will air, and

the questions we have for you in a possible interview.

Best regards

/Joachim






November 2, 2017




To: Joachim Dyfvermark <[email protected]>

Cc: Nils Hanson <[email protected]>, Sven Bergman <[email protected]>

Subject: Re: SV: EF Response to Uppdrag granskning

Dear Joachim:

Thank you for your email. As I mentioned to you before, I am traveling this week.

I will talk to my office tomorrow and I promise to respond no later than tomorrow evening,

which should provide you with answers before your new deadline.

Best regards,

Martha

Sent from my iPhone






x-apple-data-detectors://1/

November 3, 2017



Date: November 3, 2017 at 6:37:55 AM EDT



Subject: SV: SV: EF Response to Uppdrag granskning

Martha,

I have an urgent question, and a suggestion.

You write:

“Our present aircraft are manufactured by Dassault in France, outfitted in the US, imported to Denmark, and operate

under an AOC.”

According to the Swedish authorities you flew with NCC, with “Go Ahead International Ltd “(Bermuda) as registered

company.

I have tried many times to get to talk to EF staff about the planes, for weeks. The fact that I don’t get to speak to any of

your people who has details over the flight set up – on a research level, NOT interview – will have a negative impact on

the outcome. It will be bad for you and for us.

I suggest you give me a name and a number to the person responsible for the jet plane set up so that I can talk to

her/him TODAY, Friday.

And then we can do a telephone interview with you or Bertil Hult, Saturday.

Best regards

/Joachim






November 3, 2017




To: Dyfvermark Joachim <[email protected]>

Cc: Evangeline Frey Kraus <[email protected]>, "[email protected]" <[email protected]>, "[email protected]"

<[email protected]>

Subject: EF's Response to Uppdrag granskning

Dear Joachim:

Attached please find EF’s response to your email dated November 1, 2017.

Best regards,

Martha

Sent from my iPhone









November 3, 2017


Dear Mr. Dyfvermark:

Please find below EF’s response to your email dated November 1, 2017.

I would like to start by repeating what I have written to you before:

PRESENT AIRCRAFT WITH “OY” TAIL NUMBERS: Our present aircraft are manufactured by Dassault in France, outfitted in the US, imported to Denmark, and operate under an AOC. We pay VAT or the "high fuel price" on all private flights where appropriate.

PREVIOUS AIRCRAFT, INCLUDING VP-BEH: All our previous aircraft were manufactured by Dassault in France, outfitted in France, the US or Switzerland, made their maiden flights to London, imported to England for EU VAT purposes, and operated under a Bermuda-registered NCC. They were all owned by Dassault and leased to us. After the leases expired we had the option to either return them to Dassault or to buy them. They have so far all been returned to Dassault.

DIFFERENCE BETWEEN AOC AND NCC: We think that you may not have the full understanding of the difference between an AOC (Air Operator Certificate) and a NCC (Non Commercial Complex). Flying under a NCC is not common in Sweden; it is more expensive because the aircraft are subject to EU VAT and in addition you pay VAT or the “high fuel price” both for business and private flights. However, flying under a NCC gives you significantly more flexibility than flying under an AOC.




CHALLENGE ASSOCIATED WITH FLYING UNDER A NCC One problem we have encountered with a NCC in this country (USA) and in several European countries is that because NCC is a non-commercial aircraft, we are not allowed to charge any of our passengers for their flights. This presents a challenge when members of the Hult Family or other EF executives have invited business friends or private friends to fly with them and those passengers want to pay for their flight. This is not possible as it is unlawful under the NCC rules. Our present aircraft operates under an AOC. They are therefore commercial aircraft, which means that the passengers who fly on these aircraft can be invoiced if they would like to pay for their flight.

FACTS ABOUT VP-BEH: A lease contract was initially negotiated between Dassault and Go Ahead Vacations Ltd in 2002—seven years before Dassault could deliver the aircraft. This was because it was a completely new aircraft model, and Dassault wouldn’t start production until they had a certain number of pre-orders for purchase or lease.

Our lease agreement was amended several times in 2006 and 2008 while Dassault made some changes to the production of the aircraft. At that time we changed the name of the lessee to Volo Ltd (Volo is Latin and means, “I am flying”).

The aircraft (a Falcon 7X with serial number 21) was manufactured by Dassult in Bordeaux, France and flown "green" (just the cockpit was outfitted – nothing else inside the aircraft) from Bordeaux to Little Rock, Arkansas, USA, on a French registration number, where the outfitting took place.

In January 2009, the aircraft was flown under French registration from Little Rock to Hamilton, Bermuda and delivered to us.

The aircraft's serial number 21 was registered in Bermuda with our Flight Operator Go Ahead International Ltd (not to be confused with our original signatory Go Ahead Vacations Ltd back in 2002) and got its registration number VP-BEH.

In mid-January 2009, the aircraft flew from Hamilton to London England, UK.

On January 20, 2009, the aircraft was imported to England/UK, for EU VAT purposes as follows:

ONE DASSAULT FALCON 7X CIVIL AIRCRAFT REGISTRATION NO VP-BEH SERIAL NO 021



After that day, we flew the aircraft on a lease from Dassault until September 2017. During the lease term, the aircraft flew for 4502 hours and made 1438 landings. All operational costs were covered by different EF entities and Bertil Hult privately. There has never been any profit generated in Bermuda or anywhere else through this lease agreement.

Your statement that the aircraft was sold in July 2017 is wrong.

The aircraft was delivered back to Dassault in September 2017. It was not sold. We did not receive any payment or a cost reduction on the next aircraft from Dassault. The aircraft was simply delivered back at the end of its lease.

Best regards,





November 3, 2017





Cc: "'Evangeline Frey Kraus'" <[email protected]>, <[email protected]>, <[email protected]>

Subject: SV: EF's Response to Uppdrag granskning

Dear Martha,

Thank you for your reply. Very informative about the plane.

And how about the telephone-interview? We have tomorrow – Saturday – that is the last day of editing.

Best regards

/Joachim







November 6, 2017



Date: November 6, 2017 at 2:34:18 PM EST


Cc: "'Evangeline Frey Kraus'" <[email protected]>, <[email protected]>, <[email protected]>

Subject: Swedish Television, Uppdrag granskning

Dear Martha,

On Wednesday November 8 our investigation about EF´s offshore structure will be aired. We normally provide quotes to people involved in our investigations, and sometimes parts of the narrative – depending on the content and the context (sometimes we don’t because sources are in a vulnerable situation before publishing).

In order to reduce the difference between what you see and what we air we will send you parts of our script, the relevant parts concerning Bertil Hult and EF, in Swedish. I know that most of the key people at EF are Swedish so it shouldn´t be a problem.

In the end of the program the show host/reporter will declare that Uppdrag granskning have found no illegal structures and transactions. If you wish to respond to the script attached we can also publish your letter online, and the show host/reporter can refer to your letter about EF´s position. If you don´t we will provide the answers you have given in our previous correspondence.

Deadline for comments is Wednesday Nov 8, 06:00.

Best regards

/Joachim Dyfvermark











Dear Martha,

On Wednesday November 8 our investigation about EF´s offshore structure will be aired. We normally provide quotes to people involved in our investigations, and sometimes parts of the narrative – depending on the content and the context (sometimes we don’t because sources are in a vulnerable situation before publishing).

In order to reduce the difference between what you see and what we air we will send you parts of our script, the relevant parts concerning Bertil Hult and EF, in Swedish. I know that most of the key people at EF are Swedish so it shouldn´t be a problem.

In the end of the program the show host/reporter will declare that Uppdrag granskning have found no illegal structures and transactions. If you wish to respond to the script below we can also publish your letter online, and the show host/reporter can refer to your letter about EF´s position. If you don´t we will provide the answers you have given in our previous correspondence.

These are the following parts, and following script regarding Bertil Hult/EF:

//START//

//…//

Det här är Bertil Hult, grundare av språkresekoncernen EF – Education first - och en de rikaste svenskarna i världen. Och nära vän med kungafamiljen.

Superentreprenören som började sälja kläder från Östeuropa till skånska turister, och som sedan mitten av 60-talet byggt upp ett språkimperium som enligt EF själva har verksamhet 116 länder – med över 40.000 anställda.

Han sägs vara god för över 35 miljarder kronor, en doldis som sällan ger intervjuer, men som beskrivs som en lyxlirare – känd för sina storslagna fester med inhyrda artister som Janet Jackson, Elton John och Rod Stewart, å sina lyxyachter – och exklusiva jetplan.

//…//

Bromma flygplats, i Stockholm. Här ska Bertil Hult ha en hangar till sina två jetflygplan.

Telefon Flygtekniker

- Reporter: Är det du som har hand om Bertil Hults plan.

- Jag jobbar som flygtekniker, har hand om och har hand om. Jag lagar dom när dom är trasiga.

- Reporter: Ja… Jag försöker få fram så mycket information som möjligt om ett Falcon 7X, med

registreringsnummer VP-BEH.

- Ja?

- Reporter: Det beskrivs som Bertil Hults plan, men enligt den dokumentationen som jag har så

ägs det av ett bolag på Bermuda.

- Det har jag ingen aning om, ägarstrukturen alls. Det kan jag vara helt ärlig och säga det har

jag ingen aning om. Du får vända dig till EF antar jag…

November 6, 2017 Email attachment from Joachim Dyfvermark (Uppdrag granskning) to Martha H. Doyle (EF Education First)


//…//

När vi i Paradisläckan spårar Hults plan - som flög kronprinsessan - hamnar vi här - ironiskt nog - på Victoria Street 22 - på skatteparadiset Bermuda. Men Bertil Hult bor inte här, och inte är det nåt EF-kontor heller. Här finns istället juristbyrån Appleby, vars interna läckta handlingar är grunden till Paradisläckan. En byrå som har som affärsidé att hjälpa stora bolag och förmögna personer att undvika skatt. Och där en av kunderna sedan många år är Bertil Hult och EF.

(Orbis bolagsdatabas)

Kartlägger man Bertil Hult och EF får man en lång lista med bolag – med säte runt om i världen - där EF bedriver sin normala verksamhet. Det är här Bertil Hults EF drar in pengar.

Men de tusentals sidor som rör Hult i paradisläckan avslöjar en alternativ struktur. Vi hittar över 25 bolag i olika skatteparadis, främst på Bermuda.

Grafik: EXELENZ HOLDING LTD Volo LTD Black Bear LTD Alpha Efekta LTD Blue Bear LTD Brown Bear Ltd Efekta Bridge Ltd Efekta Insurance International Ltd Efekta Spires Ltd. Efekta REEF Ltd. Efekta Rose Ltd. Englishtown ltd Go Ahead International Ltd. Hult International Business School ltd Ivy Education Ltd. Longjump Ltd. Oldtown Ltd. Pilatus Ltd Polar Bear ltd Private S.Y. Erica XII Ltd.– (Bermuda) Private S.Y. Erica XII Ltd. – (MALTA) REEF Ltd. Rushmore Ltd. Signum International Ltd. Signum lnternational S.a.r.l

Det är till stora delar en hemlig struktur. Omöjlig att se om man inte har tillgång till de interna dokumenten.

Här finns bolagshandlingar, styrelseprotokoll och i bolag efter bolag garantier om total skattebefrielse.

//…//



Men hur var det då med Hults plan? Jo, dom registrerades på Bermuda, av brevlådeföretag omgärdade av anonymitet och sekretess. Och administrerades härifrån Appleby.

//…//

ERICA XII, 52 meter lång - med plats för 10 passagerare utöver de 7 i besättningen.

Inte heller den ägs direkt av Bertil Hult eller EF.

Den ägdes först av ett brevlådeföretag på skatteparadiset Bermuda och administrerades av Appleby, nu har den flyttat till ett brevlådeförtag på Malta. Som med sina låga skatter blivit en populär flaggstat för lyxyahter.

//…//

Dokumenten i Paradisläckan avslöjar hur pengar flyttas från EF:s operativa bolag till bolagen i skatteparadis. Vi ser avtal där brevlådeföretagen sedan lång tid tillbaka tagit betalt för royalites, serviceavtal och licenser.

På så sätt minskas vinsten – och därmed skatten - för de EF-bolag som finns i länder med högre bolagsskatt.

//

Ett exempel. Bolaget Signum international i skatteparadiset Luxemburg, äger rättigheterna till några av EF:s varumärken, och har vinster på hundratals miljoner kronor de senaste åren.

Bolaget ägs i sin tur av brevlådeföretaget Blue Bear ltd på Malta, som i slutänden ägs av Bertil Hult själv. Genom en kedja av utbetalningar har Hult under de tre senaste åren tagit ut motsvarande drygt 300 miljoner kronor i aktieutdelning – bara i den här strukturen.

//…//

Vi är tillbaka i Luzern. Här längst upp i lyxhotellet på Haldenstrasse 4 finns hjärtat av Hults EF-imperium.

Vi har i förväg sagt att vi kommer, och flera gånger bett att få intervjua Bertil Hult, eller någon i ledningen för EF.

Live: - Hello, Swedish Television- Welcome- Thank you- I told them that I would be coming, do you have any one from the financial

department?- Financial department… I can maybe check if someone is here who can meet you.

Because, from the from the finance team, otherwise…- Yes, please



- If you don´t have a meeting I am sorry…- ok- Let me see.- ok- Let me check- Thank you- You can take a seat over there.- Thank you.

SPEAK Beskedet inför besöket har hela tiden varit detsamma. EF svarar på frågor via mejl, eller via en talesperson i USA. Men vi vill visa några av de hemliga dokumenten, gå igenom sifforna med Bertil Hult, eller nån annan i ledningen som ansvarat för upplägget.

LIVE (Fredrik Manse EF) - Hello!- Hi!- Hi!- And this is?- I am Fredrik Manse, and who are you?- Joachim Dyfvermark- jaha- Är du svensk?- Jag är svensk.- Vad trevligt!- Vi har tittat på EF under ett par månader, dels den officiella strukturen, dels den som

ligger i skatteparadis. Och de interna dokument som vi har kan jag av källskyddskäl inteskicka till er. Däremot så är jag är här nu och kan visa den som besitter den kunskapenoch gå igenom detaljerna. Det är därför jag är här.

- Jag förstår, men tyvärr som Evangeline har svarat så kan dom hjälpa om du skickarfrågor till oss. Och sen kan du få prata med Martha Doyle i Boston har jag förstått. Detär den vägen vi har valt att gå.

- Njut av Lutzern… solen skiner, det är härligt.- Det låter som ni inte är intresserade att veta vad vi kommit fram till?- Absolut, det… säkert men som Evangeline har svarat tidigare så ber hon att om du

skickar frågorna så ska vi svara. Svara på dom frågorna.- Tack.- Thank you, sorry for disturbing.- No worries, have a good day.

//…//

Luzern i Schweiz, här ska den medieskygge Bertil Hult bo. I över 3 veckor har vi försökt att få en intervju. Utan resultat.

Istället får vi svar från EF via mejl.

Citat:



Our worldwide structure reflects the activities which take place in the various countries where we are present, and the structure is not set up to “avoid tax” as you speculate.

EF skriver att Hults yacht och flyg inte varit registrerade på Bermuda av skatteskäl, att Hult betalt för alla resor han gjort privat, och att man skattat enligt gällande regler.

Men nån intervju blir det inte. Med någon från EF.

(Arkiv)

Vi får gå tillbaka till arkiven. 2013 porträtterade Uppdrag granskning Bertil Hult, och redan då ställde vi frågor om EF:s skatteupplägg.

Ur Uppdrag granskning 2013

Arkiv Martha Doyle talesperson EF

- What I can tell you is, we couldn't have grown to the size we are without running a reputable

ethical business - as I say our structure has grown primarily out of the fact we are founded by

one man and he moved around quite a bit and we have been growing with him.

TG Bertil Hult Rapport 16/8 2006

Arkiv Bertil Hult

- Jag ser ingen uppsida att prata på att berätta för människor om vår struktur och vad vi säljer

för och vad vi tjänar. Vi ser inte att det kan gynna oss på något sätt. Vi kan däremot se att det

kan missgynna oss, och då är det bättre att inte berätta det.

Bertil Hults Falcon 7X med registreringsnummer VP-BEH avregistrerades från Bermuda den 16 oktober i år. Hult uppges nu ha ett nytt plan. Den här gången registrerat i Danmark.

//END//

Utöver våra speakertexter kommer kritik från medverkande som vi väljer att inte namnge före programmet. Kritiken kan sammanfattas:

Uppläggen, med bolag i skatteparadis och lågskatteländer som drar in pengar från den operativa verksamheten är att klassa som aggressiv skatteplanering.

Det är inte olaglig verksamhet.

Det finns en kunskap inom EF att bolaget vill betala så lite skatt som möjligt, delar av personalen är medveten om skatteplaneringen.

Det finns en strategi att omvärlden och personalen inte ska veta hur mycket pengar EF omsätter.



From: Martha Doyle Sent: Tuesday, November 7, 2017 5:13 PM To: 'Joachim Dyfvermark' <[email protected]> Cc: Evangeline Frey Kraus <[email protected]>; [email protected]; [email protected] Subject: RE: Swedish Television, Uppdrag granskning

Dear Joachim,

Attached please find EF’s response to your email dated November 6, 2017.

Separate from the attached letter, we will be sending you a PDF file which includes a compilation of all our previous communication. We would like that document (which includes all prior communication) to be considered as the official response from EF to Uppdrag granskning. We would also like it to be published online in its complete form as you have offered. Note that EF’s response is only complete if it includes the full history of our communication.

Best regards,

Martha

Martha H. DoyleChief Administrative Officer



November 7, 2017Email from Martha H. Doyle (EF Education First) to Joachim Dyfvermark (Uppdrag granskning)






November 7, 2017


Dear Mr. Dyfvermark:

Thank you for the opportunity to comment on your “Bev till EF inför sändning.”

Although we appreciate this gesture, we are disappointed to see that this document still contains incorrect information and statements because we spent so much time and effort to provide you with the facts.

Over the last three weeks, we have continuously provided you with answers to every single question you have asked, and we have offered you an in-person interview with me as your colleagues at Uppdrag granskning did a few years ago.

It is inconceivable to us that after you have been given all the facts, you are still planning to broadcast content that is incorrect.

We have enclosed a compilation of all communication between EF and Uppdrag granskning since you first contacted us on October 6, 2017, and we have highlighted below a few facts that you ignore or misrepresent in parts of your “Bev till EF inför sändning.”

Bertil Hult has never owned any airplanes. EF has never owned any airplanes. Theairplanes, which have been leased by EF, have been owned by Dassault USA or DassaultFrance.

Bertil Hult does not live in Bermuda. Nor does he live in Sweden. Nor does he live in anyof the other 50 countries where EF has offices, with the exception of Switzerland wherehe has lived for over 20 years and where EF has 600 employees.

EF has legitimate business offices in Bermuda and in all other countries in which EFoperates.

According to the Bermuda/UK authorities, Appleby was criminally hacked; it was not aninternal leak.

November 7, 2017Email attachment from Martha H. Doyle (EF Education First) to Joachim Dyfvermark (Uppdrag granskning)



Neither EF’s nor Bertil Hult’s companies have any “secret structure” in Bermuda,Luxemburg, Malta or any other countries. EF is a private company owned entirely by theHult Family, and we do not share corporate information with media. We are, however,fully transparent toward authorities and other relevant counterparts.

It is incorrect to say that EF moves money to “tax havens” in order to avoid taxation inhigher tax countries. In every country in which we do business, we operate in fullcompliance with the applicable tax legislation, and equally important, with its full intentand purpose.

We would like this response, which includes all prior communication, to be considered as the official response from EF to Uppdrag granskning. We would also like it to be published online in its complete form as you have offered. Note that EF’s response is only complete if it includes the full history of our communication.

I would like to inform you that several Swedish media have asked me to send them the same information that we have provided to you. However, as a matter of courtesy, since you and I have been corresponding for several weeks, I have decided to wait to share this information until after your show has aired.

We continue to trust that SVT will not air a story based on speculations and material that is incomplete or incorrect.

Best regards,



November 7, 2017Email attachment from Martha H. Doyle (EF Education First) to Joachim Dyfvermark (Uppdrag granskning)


history of communication between ef education first and … · 2017. 11. 9. · october 11, 2017...

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