Björn accused of not paying his taxes

The ABBA-member Björn Ulvaeus is accused of withholding SEK 87.000.000 in taxes, fees and interest by Skatteverket (the Swedish equivalent to IRS). Ulvaeus is accused of "laundring" his income from his music production through a tax paradise.

- This was done when Björn moved to England and not with the intention to escape any taxes, says Sven Rygaard, Ulvaeus' lawyer.

Björn Ulvaeus has been able to assimilate large sums of money in secrecy through a capital investment insurance with the insurance company Royal Skandia on Isle of Man. It's there the royalities and the incomes from record sales both from ABBA and Ulvaeus' own music production has ended up. All through a net of different trustfunds, a company in Holland and several other companies in the tax payers' paradise the Dutch Antillies.

As far back as the 1970-80's the first of many contract were drawn up, through which Björn Ulvaeus sold his copyrights to different companies. The deal that Skatteverket is criticising now looks like this:

From 1990 has Ulvaeus rights become collected in a Dutch company which nowadays is called Fintage. The company made a deal with the tax payers' paradise company Stanova, in the Antillies which included that 95% of the royalties [Ulvaeus earns] should go there. From Sweden goes all of ABBA's two record companies Polar Music and Universal to Fintage, and from there to Stanova. Stanova is owned by another tax payers's paradise company as a middle man (UPI) by the capital insurance in Royal Skandia.

Björn Ulvaeus has access to the money through re-buying shares from the capital insurance.

All together there has been, according to Skatteverket's calculations for the years 1998-2003, withdrawals to the amount of SEK 94.9 million in royalties to the Dutch company Fintage and further down the construction of the company.

Björn Ulvaeus moved to England from Sweden in 1984, but now lives, since many years in Sweden again.

Skatteverket's standpoint is that these contracts, through which he has signed over his right should be considered a diversion, that he is in fact running a business and there for shall pay taxes for the royalties.

Skatteverket are quoting Ulvaeus point of view in their decision: "you write that... the reason naturally has been to transfer the rights to the companies that you own... and that creating a good situation for that so that the trade currents will benefit the capital insurance."

The companies in the Atilles has dummies (bulvaner) who represent them, but Skatteverket has managed to connect them to the Royal Skandia insurance.

Björn Ulvaeus advisor, lawyer Sven Rygaard:
- This is what is going on. We are having discussions with Skatteverket about the years 1999-2003 where we have different views on a lot of things. Rygaard does not want to go into details about this financial construction.

- Skatteverket's grounds for the decision is based on that Björn hasn't signed over his rights, but they are - by the book. It was because of English reasons this was made when Björn moved to England in 1984, he says.

- That is what Skatteverket has reacted to now. Naturally we have appealled this decision. We are quite confident that it will go our way.

Skatteverket has, as Dagens Nyheter has written about in many other cases - focused more on where the money ends up than how they are being transported around.''

Why was this construction still at work when he moved back to Sweden?
- He *had* sold the rights to one company. It's not you do in a very easy way, he has no controll over the money in Holland, says Sven Rygaard.

But he still gets money from his Capital insurance?
- Yes, but if you sign away your right to your work to a company and then has a change in your salary, then you have still signed over your rights.

Björn Ulvaeus will be back taxed for income from business during five years, 1999-2003. The tax, the pennalty tax and the inerest he will have to pay is SEK 86,9 million (approx USD 10.000.000.

- Will give Skatteverket a reply and an explanation on how this has happened, I simply don't think they have managed to understand all the deals involved in this, says Sven Rygaard.

Björn Ulvaeus reported SEK 2.000.000 as income in 2003.

By Juan Flores DAGENS NYHETER