HSBC India Chief Executive Officer Stuart Paterson Milne held shares in two Panamanian entities, Walton Investments SA and Robaco Incorporated.
Shares in both these entities were transferred to Milne on December 4, 2014. The original shareholders were not mentioned in the Mossack Fonseca files made available by the International Consortium of Investigative Journalists (ICIJ) to all its members, and investigated by The Indian Express.
The files reveal these were ‘Bearer’ shares. The Panama tax jurisdiction allows entities to issue ‘Bearer’ shares, where the owner(s’) name(s) are not mentioned in the share certificate. Simply put, whoever physically possesses these shares is the owner too.
Robaco Incorporated had issued two ‘Bearer’ share certificates on May 27, 1983, each representing 5,000 shares. The face value of each share was $ 1.
Walton Investments too had issued two share certificates on October 8, 1985, each representing 5,000 shares. The shares of Walton also carried a face value of $ 1 each. All the shares of both the entities was transferred to Stuart Milne on December 4, 2014, who further transferred them the very next day — December 5, 2014 — to Fortress International Services Limited as trustees of the Robscot Family Trust.
When contacted, Stuart Milne told The Indian Express, “These companies were established some years ago by my late father. All of my tax affairs are declared in full to the Indian tax authorities in line with their requirements.”
According to Mossack Fonseca files, both Robaco Incorporated and Walton Investments hold property, and their activity takes place in the Isle of Man and the United Kingdom. A meeting of shareholders of Robaco and Walton on February 24, 2015, appointed MF Legal Services as the registered agent for the two entities, and Rachel Walsaw and Edward Bannett as directors in both the entities.