An ordinary former council house in an ordinary Fife street.

It does not look like the headquarters of a multinational firm.

But this semi is the official address of the Brook Organisation, a limited partnership which the Latvian media has reported is at the heart of a major corruption scandal in the country involving the nephew of Uzbekistan's hardman president Islam Karimov.

In fact, the property is also home to at least 64 other businesses.

Welcome to the world of offshore Scotland, Europe's unlikely tax haven, where council schemes play a role most people associate with palm-fronged beaches of Caribbean fiscal paradises.

Pictured: The Seychelles, the more typical image of a tax havenHeraldScotland: Seychelles: an island paradise fit for royalty

Thousands of limited partnerships have been created in Scotland in recent years to satisfy a nearly insatiable desire for the firms in eastern Europe, where they are advertised as tax avoidance vehicles.

The unique firms - typically sold off the peg - alongside parent partners registered in more traditional tax havens like the Seychelles, Panama or Belize - do not need to pay tax in the UK if they do no business here.

Crucially, unlike their English and Welsh counterparts, Scottish limited partnerships or SLPs do not need to provide full financial reports.

Senior Scottish law enforcement officials are alarmed by the mushrooming SLP business.

Last year it emerged that SLPs - again registered in modest homes in provincial Scotland - had been used to funnel $1bn out of banks in the former Soviet republic of Moldova, Europe's poorest country.

The speaker of the Moldovan parliament leaked an independent report naming SLPs, including one based in an unglamorous address in Pilton, Edinburgh, as being the vehicles for the fraud. Moldova had to bail out the banks. The rescue package cost the country the equivalent of one eighth of its gross domestic product.

Full background to Moldova bank fraud investigation.

Pictured: Moldovan tycoon Ilan Shor, accused of using SLPs in fraud


One home in Leith was found to be being used as the address of 3600 firms, including SLPs.

Law enforcement sources suspect that SLPs are being used for money-laundering and facilitate corruption and embezzlement overseas. Tax investigators from HMRC and Police Scotland's Organised Crime and Counter-Terrorism Unit last year raided five addresses in Fife and the Lothians which were being used as official addresses for more than 1500 firms.

That did not stop intense advertising of Scotland as a tax haven and intense marketing of SLPs. Earlier this year The Herald found, for an example, an advertorial on Belarus television station Varyag.

It said: "A company operating in the UK does not need to register with the tax authorities and is therefore automatically freed from any tax payments on an absolutely legal basis.

"Having registered a company in Scotland, by using offshore rules, you do not need to carry out any audits and, furthermore, there is no requirement to provide financial reports."

The TV station stressed the kudos of Scotland being in Britain. "As a result of Scotland being part of the United Kingdom it does not fall in to the black list of offshore zones."

SLPs , which date back to the Limited Partnerships Act of 1907, are still not required to disclose their annual accounts or even the names of the people who control them.

Ownership and control can be masked through faceless "general partners" and "limited partners", and these are often based in secrecy jurisdictions like the Marshall Islands, British Virgin Islands, Cayman Islands, Belize and the Seychelles.

Labour and the Greens have both called for a review of Scottish limited partnerships, which are subject to UK company law. Justice Secretary Michael Matheson has also expressed concern about abuse of such firms.


What is a “Scottish offshore company”?

In theory, there is no such thing. The Scottish offshore companies, marketed as off-the-peg shelf firms in eastern Europe, are, in fact, limited partnerships. However, company creation specialists have devised a way for such partnerships, when they are owned by two partners based in classic tax havens, to act, effectively, as offshore entities.

So what is a Scottish limited partnership?

These date back to a 1907 Act that created limited partnerships that, unlike otherwise similar entities in England and Wales, had their own legal personality. That means that they can enter in to contracts, sue, borrow and own assets. Scottish limited partnerships do not need to provide full regular financial reports and, if they carry out no business in the UK, do not need to register for tax. Some brokers in Ukraine and Belarus refer to them as “Scottish zero-percent-tax firms”.

Who buys them? Criminals?

Not necessarily. Business people in unstable countries on the fringes of Europe like the kudos of a Scottish company, safe within the European Union and United Kingdom, to protect their assets from the taxman or even unscrupulous rivals.

Why does the law allow them?

Supporters of SLPs say they make good investment vehicles, because they have that unique Scottish quality of being able to own assets.

Can Scotland stop the creation of SLPs?

No, company law is not devolved so the UK Parliament would have to amend legislation.