Lender Nykredit, from its Marbella office, and its business partner Sydbank, from an illegal Fuengirola office, persuaded British pensioners to take out offshore companies as part of a IHT tax avoidance scheme.

The “Equity Release Package” or Equity Release Product, as was named by the advertising literature, consisted on a loan granted by Nykredit -Christel Mark Hansen acting for the latter- guaranteed on a Spanish property, the proceeds of which loan were invested via Sydbank in Switzerland -with the assistance and supervision of Mads Petersen-

Sydbank would provide a guarantee to its business partner Nykredit for 33% of the loan, who would pay for the privilege, so as to ensure that the lender was fully covered.

To achieve full anonymity, Sydbank in Switzerland offered offshore company to shelter the investments and make it more difficult for the Spanish Tax Office to find out the whereabouts of the loan proceeds, now presumably invested.

Nykredit and Sydbank sold this product as a legal, lawful manner to achieve state-of-the-art wealth planning for retired British property owners in Spain.

The highly opaque offshore companies were incorporated in Belize and had directors posted in New Zealand.