Brian Tonna signed a sale-of-Maltese-citizenship agreement with himself

Information and documents in the Panama Papers show that Brian Tonna, the corrupt accountant at the centre of this storm of scandal, incorporated a company in the British Virgin Islands in June 2013, in which his identity as ultimate beneficial owner was thoroughly concealed behind nominees provided by Mossack Fonseca in Panama.

This makes his claim that he owns Egrant Inc, which was acquired at around the same time, more ridiculous still. There were four companies set up at that time: Egrant Inc, Tillgate Inc and Hearnville Inc (Muscat, Mizzi, Schembri) in Panama, and Willerby Trade Inc (Tonna) in the British Virgin Islands.

In March 2014, Willerby Trade Inc – which is solely owned by Brian Tonna – entered into an agreement with BT International Ltd, a company incorporated in Malta and wholly owned by Tonna, to refer prospective clients for the purchase of Maltese citizenship.

You can read the agreement, which is found among the documents in the Panama Papers, by clicking here.

For every client referred by Willerby Trade Inc to BT International Ltd, who then went on to buy Maltese citizenship, Willerby Trade would get “50% of the agreed fee between BT International and the prospective client”.

While having one company invoice another to share the same fee, when you own both companies, on the face of it looks entirely pointless, you have to remember that nobody knew Brian Tonna owned Willerby Trade Inc, and nobody would ever have been able to know, before Mossack Fonseca’s server in Panama was stripped of its entire tranche of millions of top-secret documents.

By pretending that his concealed-ownership British Virgin Islands company had referred clients to his Maltese company, and having it invoice his Maltese company for 50% of the fees, Tonna was able to set off invoices from Willerby Trade Inc against BT International Ltd’s income, reducing that income for declared tax purposes in Malta.

BT International Ltd would then pay out 50% its income to Willerby Trade Inc, on which Willerby Trade paid no tax in Malta or elsewhere because ownership of the company was concealed by Panama nominees and the company itself was incorporated in the British Virgin Islands. Tonna then got to keep the entire 50% paid to Willerby while being subject to tax only on the 50% retained by BT International Ltd.

This all emerged last year and I had reported on it, including the fact – discovered through a source and not through the Panama Papers – that Willerby Trade Inc has an account at Pilatus Bank.

Left to right: Brian Tonna, Joseph Muscat and Karl Cini at the opening of Nexia BT’s new offices four years ago, when Muscat had just become prime minister.