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摩根士丹利(MS.US)因逃税遭荷兰处以1.01亿欧元罚款
智通财经网· 2025-11-27 13:31
Core Points - Dutch prosecutors imposed a fine of €101 million (approximately $117 million) on Morgan Stanley for dividend tax evasion and submitting false tax returns [1] - The fine relates to "Cum-Cum transactions" involving Morgan Stanley's subsidiaries in London and Amsterdam, which allowed foreign stockholders to lend securities to local tax-exempt entities to avoid withholding tax on dividends [1] - Morgan Stanley allegedly designed transaction structures that enabled ineligible entities to unlawfully benefit from tax credits or refunds on dividend taxes [1] Company Summary - Morgan Stanley established a Dutch subsidiary between 2007 and 2012 to temporarily hold stocks during dividend distribution periods, earning a total of €830 million in dividend income [1] - The company claimed a total of €124 million in withholding tax credits on its corporate tax returns from 2009 to 2013 related to these transactions [1] - A spokesperson for Morgan Stanley expressed satisfaction with resolving this historical matter, which pertains to tax returns submitted in the Netherlands 12 years ago [2] Industry Context - European prosecutors are increasingly focusing on dividend stripping transactions, which have generated hundreds of millions of euros in dividend income for banks, with some countries deeming them illegal [2] - Criminal investigations have been initiated against several banks, including BNP Paribas, HSBC, and Société Générale, in France for similar practices [2] - The French tax authorities are seeking to recover at least €4.5 billion in tax losses and have expanded their investigations to include major Wall Street investment banks like Goldman Sachs and Bank of America [2]