The Ghost of the Golden Triangle, Luxembourg and the late Bugatti Museum

The Ghost of the Golden Triangle, Luxembourg and the late Bugatti Museum
The Ghost of the Golden Triangle, Luxembourg and the late Bugatti Museum

The “phantom of the Golden Triangle” is now only a shadow of itself. Not only was Adrien Labi, millionaire of Syrian origin and holder of a British passport, arrested by the French authorities, but 17 of the 25 properties that are in his real estate portfolio are not located in the mythical Golden Triangle district. , bordered to the north by Avenue des Champs-Élysées, to the east by Avenue Montaigne and to the southwest by Avenue George V.

Last week, the French authorities ended up getting their hands on the one they had been investigating for almost seven years during a trivial transaction. From Crans Montana or Los Angeles, he no longer came by plane so as not to be arrested at a Parisian airport, but by car from other continental airports. The Central Office for the Fight against Corruption and Financial and Tax Offenses opened an investigation in 2015 following two complaints from the tax authorities for non-payment of income tax, solidarity tax on wealth and real estate wealth tax.

A real estate portfolio of more than 1.7 billion

Placed in police custody last Tuesday and targeted by a judicial investigation the next day, he was indicted for tax evasion and omission of accounting entry in 2010 and 2011, as well as for tax evasion and money laundering of this offense between 2018 and 2022. Tax evasion was not a primary offense of money laundering until then in Luxembourg, which perhaps explains the length of the procedure. Presumed innocent in the eyes of the law, he was placed under judicial supervision with a mandatory bond amounting to 30 million euros.

On February 24, adds the secretary general and communication officer of the French National Prosecutor’s Office, the PNF had opened a preliminary investigation for suspicions of money laundering in an organized gang of aggravated tax fraud, relating to the reuse of undeclared real estate capital gains.

At the time of the police custody, seizures amounting to 461 million euros were made in the two procedures to guarantee the payment of a possible fine and the regularization of his tax situation. According to AGRASC, they represent an entire year of seizures across the whole of France.

From 940 million euros in 2015, according to a long and fascinating survey that Le Monde then devoted to him, the value of his real estate assets rose to 1.7 billion euros, according to the latest annual report of the financial Triangle of APS Gold, the Danish company he registered in 2008.

The most spectacular example of a recent operation is the announced sale of 64-66 rue Pierre-Chaurron to Credit Suisse for 200 million euros. But the financial package between Paris and Luxembourg does not bear witness to the often quoted 25,000 euros per square meter. Firstly because the Swiss bank only communicated on 32,000 m² out of the 76,000 m² of this double address, but also because the “64” remains within the perimeter of the Danish company according to the last annual report published at the end of December.

One tax treaty, two interpretations

Why go to Denmark in 2008? Probably because his tax specialist or his Luxembourg lawyer advised him to do so. With the Paris Premier Properties (PPP) holding company, Adrien Labi had begun to register companies in Luxembourg to take advantage of a judgment by the French Council of State and then by the Luxembourg Court of Appeal which had introduced a doubt into the interpretation of the tax treaty between the two countries: each thought that it was up to the other to tax income or capital gains from real estate in France.

Only in 2008, a wave of panic seizes Luxembourg: the tax treaty is renegotiated and the legislator is more precise on the place of taxation. Many studies and many tax experts then kindly designated Denmark as a new El Dorado. Exactly for the same reason: a vagueness on the taxation of real estate in the agreement between the two countries, France and Denmark.

With the exception of PPP and Tempolux (which will go bankrupt in 2019), the businessman has already closed the others and is rushing into the breach for the capital gains and income from his real estate portfolio. He is keeping PPP as a pied-à-terre in Luxembourg only to continue to take advantage of another mechanism: the exemption from taxation at 3% for assets held in a company controlled by a financial institution.

Cardif Lux Vie stuck by the procedure

He kept PPP but entrusted it to ABN Amro Life in two stages: on December 30, 2005, his trustee The Diamond Trust in Jersey transferred the 1,000 shares of PPP to the life insurance company linked to ABN Amro; less than a month later, he subscribed to a capital increase by taking the 2,500 new shares via contributions in kind (from real estate companies on both sides of the border); the new shares are transferred to its trustee… who transfers them to ABN Amro Life.

From the departure of ABN Amro from Luxembourg, the assets fall into the fold of BGL BNP Paribas, in which the State is a 35% shareholder. The 3,500 shares of PPP are transferred from ABN Amro Life to Cardif Life (on July 14, 2017) then to Cardif Lux Vie (in April 2021). Contacted, the life insurance company replies that it does not communicate “any information on an ongoing legal case”.

If the investigation actually started in 2015 and the company did its job well, it must have been aware of the problem related to the contract that ABN Amro Life had concluded with Adrien Labi. And if this problem had been reported to the Public Prosecutor’s Office, it is quite possible that the courts have asked the institution to maintain the commercial link with the business manager without however discussing this with him, until the situation resolves. decant.

The other legal aspect…

Less known, Adrien Labi must face a second legal component, in Italy. Particularly passionate about cars, the millionaire had decided to buy the Fabbrica Blu in Campogalliano, the mythical place of manufacture of Bugatti in Italy. After the closure and three years of work, the factory was reopened and inaugurated on September 15, 1990. A year later, the super sports car EB 110 (for Ettore Bugatti and 110 for his age), manufactured in only 128 units, came out of production. ‘factory. Alas, the success of the monocoque with the 3.5-litre V12, four turbos capable of reaching 351 km/h – making it the fastest production vehicle of its time – came to an end in 1995.


12 EB110 parked in front of the Fabbrica Blu, which Mr. Labi wanted to acquire to make it a museum to the glory of the brand born in Italy. (Photo: Bugatti)

Former Facilities Manager Ezio Pavesi and his son Enrico volunteer their time to maintain the iconic venues. Until Adrien Labi decided to buy them, via another Luxembourg structure housed at the same address, at 45 avenue de la Liberté, Fabbrica Blu, to turn them into a Bugatti museum.

Except that the transaction, which seems to have been signed, was never honored financially, indicates the former owner Romano Artioli. And the two men are in court to unravel the future of the site, which the latest report from the Luxembourg company already indicated.

The article is in French

Tags: Ghost Golden Triangle Luxembourg late Bugatti Museum