Heineken heiress finds new way to avoid Dutch taxes, sheltering billions in tax havens: NRC

Charlene de Carvalho-Heineken, the billionaire heiress to the Heineken fortune, has been channeling her vast dividends through a network of tax havens, shielding billions from Dutch authorities. When one loophole was closed at the start of the year, her advisors found a new way to further reduce her tax payments to the Netherlands, according to NRC, which outlined an elaborate tax avoidance scheme after a months-long investigation.

The report comes a few weeks before the annual Heineken Holding shareholders' meeting. De Carvalho-Heineken is expected to attend as the firm's largest shareholder and executive director.

Currently the richest person in the Netherlands, De Carvalho-Heinkenen's wealth was estimated at about 16 billion euros by the newspaper. De Carvalho-Heineken, the sole heir to her father Freddy Heineken's brewing empire, reportedly receives hundreds of millions of euros annually in dividends from her Heineken shareholding. According to Dutch law, a 15 percent dividend tax should be applied to these earnings.

However, NRC's investigation found that De Carvalho-Heineken has been utilizing a complex web of letterbox companies and foundations in Luxembourg and Jersey, notorious tax havens, to significantly reduce her tax burden. Previously, De Carvalho-Heineken channeled her dividends through a letterbox company in Luxembourg before ultimately directing them to Jersey, where she only faced a minimal 2.5 percent tax rate. This practice allowed her to avoid paying tens of millions of euros annually to the Dutch treasury.

When the Netherlands implemented stricter anti-tax avoidance rules in January 2024, effectively closing this loophole, her advisors devised a new strategy. Julier BV, a Dutch company holding her Heineken shares, reportedly began "repaying" a portion of its share capital to its Luxembourg counterpart, Silvaplana SA. Unlike dividends, share capital repayments are not subject to Dutch withholding tax. This maneuver allows De Carvalho-Heineken to essentially extract her wealth from the Netherlands tax-free.

Financial experts consulted by NRC believe this new structure could enable De Carvalho-Heineken to gradually transfer 9.3 billion euros as share capital, tax-free, over the next several decades. Her tax avoidance practices extend beyond the Netherlands. While residing primarily in the UK, she reportedly maintains her official residence in Switzerland, a country known for its favorable tax treatment of wealthy foreigners. This allows her to further minimize her global tax liability.

NRC's investigation also revealed De Carvalho-Heineken's extensive use of letterbox companies in Jersey to manage her vast real estate portfolio, encompassing properties in the United Kingdom, France, and Switzerland. These companies effectively shield her identity as the owner, potentially hindering tax collection efforts in these countries.

The Heineken heiress declined all interview requests from NRC regarding her tax arrangements. Her spokesperson stated that the information pertains to her family's private life and that they will not issue a comment. Heineken Holding, the brewing giant, also declined to comment on the matter.