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Tax Evasion and Tax
Havens since the
Nineteenth Century
Edited by
sé b a s t i e n gu e x
h a dr i e n buc l i n
Tax Evasion and Tax Havens since the Nineteenth
Century
Sébastien Guex · Hadrien Buclin
Editors
Tax Evasion and Tax

Havens
since the Nineteenth
Century
Editors
Sébastien Guex Hadrien Buclin
Department of History Institute of Political Studies
University of Lausanne University of Lausanne
Lausanne, Switzerland Lausanne, Switzerland
ISBN 978-3-031-18118-4 ISBN 978-3-031-18119-1 (eBook)

https://doi.org/10.1007/978-3-031-18119-1
© The Editor(s) (if applicable) and The Author(s), under exclusive license to Springer
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Preface
This collective work aims to shed light on a history that is still largely
unknown, that of tax evasion and tax havens, since their rise in the nine-
teenth century. Since the 2008 financial crisis, the issues of tax evasion
or avoidance—and of tax havens—has gained increasing prominence in
public debate and has led to the publication of a vast amount of academic
literature. However, there is little research on the secular history of
this phenomenon. The following introduction, by Sébastien Guex, offers
some explanations for this gap. It also proposes a new periodisation of
the phenomenon, which shows that it has its roots well before the First
World War, as well as a new conceptualisation that emphasises the notion
of tax predator.
The book is then organised into three thematic parts. The first part
(seven chapters) examines the emergence and expansion of tax havens
during the nineteenth and twentieth centuries. This section also outlines
a typology of tax havens. This includes not only offshore financial centres,
investment hubs, transit countries, or conduit countries but also the little-
known reality of freeports. This question also leads to a reflection on the
competition between tax havens, for example, the Belgian and Swiss tax
havens, on the eve of the First World War. This competition includes tax
evasion by wealthy, often mobile individuals, as well as by large compa-
nies. The contributions on this subject will shed light on the strategies
v
vi PREFACE
implemented by states to attract them to their territory, for example,

through tax exemptions for rich foreigners or through freeports. Several
chapters also confront the difficult question of estimating tax evasion and
its evolution over time, a problem that has been addressed only fleet-
ingly by historians. From this point of view, several contributions mobilise
unpublished data, as well as long statistical series.
The second part (four chapters) studies the evolution of the volume
of tax evasion from a historical perspective. It examines the causes of tax
evasion, but also the social and political conflicts it has caused, particularly
in tense contexts such as world wars or economic crises. Thus, several
contributions will question the impact of the great labour and socialist
struggles in Europe after the First World War on the debates around tax
evasion. The development of the tax system and its tax control efforts are
also examined from the perspective of the political struggles they have
generated.
Finally, the third part (five chapters) examines public authorities’ fight
against—or rather complacency towards—tax evasion. It shows how the
reaction of the authorities can vary greatly, depending not only on social
and political power relations but also on the financial needs of the states,
for example, in a post-war reconstruction context. The chapters highlight
a wide range of state responses, from high tolerance to prison sentences,
as well as various measures to promote taxpayer morale. The problem of
understaffed administrations and other forms of helplessness in the face
of the complex legal arrangements implemented by some tax evaders is
also examined. This illustrates the importance of the actual tax practices
of administrations beyond the study of the legal framework alone.
This publication should be seen as a step towards a better under-
standing of the history of tax havens as a phenomenon organically linked
to capitalist globalisation. The two editors are fully aware of the limita-
tions of this publication, particularly in terms of geography, where regions
such as Asia, which is so important in the recent development of tax
havens, occupy a small part of the picture. We hope that the fact of having
brought together some twenty authors around this decisive issue for the
understanding of the contemporary world will stimulate new research.
This book is the result of a conference organised by the two publishers
at the University of Lausanne and held online in June 2021. It provided
an opportunity to discuss the contributions published in this volume.
PREFACE vii
Both editors would like to thank the participants for the richness of the
discussions on this occasion, and the staff of Palgrave, in particular Lucy
Kidwell, for the trust they have placed in us and their support during the
preparation of this book.
Lausanne, Switzerland Sébastien Guex

Hadrien Buclin
Contents
1 Introduction. “Low-Tax Predators” Rather Than

“Tax Havens”: New Perspectives on the History
of the International Tax Evasion and Avoidance Market 1
Sébastien Guex
Part I Emergence and Expansion of Tax Havens

2 The Emergence and Expansion of Tax Havens,
1850–2000: Insights from a New Dataset 37
Sébastien Laffitte
3 Emergence and Expansion of the Swiss Tax Haven:
The Tax Privileges for Rich Foreigners in the Canton
of Vaud, 1840–1959 55
Vivien Ballenegger
4 Emergence of, and Threats to, the Belgian Tax Haven
During La Belle Epoque, 1890–1914 73
Simon Watteyne
5 The Oil Multinational Shell’s History of Using Tax
Evasion Methods, Including Tax Havens and Political
Pressure, 1914–1974 93
Tijn van Beurden
ix
x CONTENTS
6 Swedish Emigration to Switzerland

in the 1960s–1980s Period: Tax Exile and Settlement
Choices 111
Thibaud Giddey and Mikael Wendschlag
7 The Rise of Tax Havens and Conduit Countries
from the Early 2000s 139
Arjan Lejour
8 Luxury Free Ports as Purpose-Built Conduits for Tax
Evasion, 1990–2020 159
Chloe Fyfe
Part II Tax Evasion: Extent, Causes, and Conflicts

9 Income Tax Evasion and Avoidance in Germany,
1850–1920 179
Marc Buggeln
10 Volume, Social Distribution,
and the Instrumentalisation of Tax Evasion
in Switzerland: The Case of Zurich, 1860–1945 201
Sylvain Praz
11 War Profits and Tax Evasion: Italian Fiscal Policies
in the First World War and After the War, 1915–1924 223
Fabio Ecca
12 Tax Compliance in a Crisis: Evidence from the Great
Depression, 1929–1936 239
Sacha Dray
Part III Fighting Tax Evasion and Tax Havens?

13 Criminalising Tax Evasion in France, Early
Nineteenth Century–2008 265
Katia Weidenfeld
14 “These Patriots Who Misuse the Law”: The
Background to the United Kingdom’s Anti-Tax
Haven Legislation of 1936 289
James Hollis
CONTENTS xi
15 Tax Evasion as Seen by French Tax Administrations

from the 1920s to the 1970s: Pragmatism in Action 317
Béatrice Touchelay
16 Detecting Ordinary Tax Evaders: The Example
of the 1945 National Solidarity Tax in France 337
Isabelle Rabault-Mazières
17 Tax Education After WWII: How Spain, the USA,
and West Germany Tried to Make Their Citizens Pay
Honestly 355
Korinna Schönhärl, Nasrin Düll,
and Nadya Melina Ramírez Lugo
Index 377
Editors and Contributors
About the Editors
Sébastien Guex is Full Professor of History at the University of

Lausanne, Switzerland. His research interests lie in social, economic, and
political history. He has been working for decades on public finance, taxes,
and tax havens, in particular the Swiss tax haven. Among his numerous
publications on these issues, one should mention L’argent de l’Etat.
Parcours des finances publiques au 20ème siècle (Lausanne: 1998), La Suisse
dans la constellation des paradis fiscaux (Lausanne/Geneva: 2002), as well
as numerous articles, for example, ‘The Origins of the Swiss Banking
Secrecy Law and Its Repercussions for Swiss Federal Policy’, Business
History Review (vol. 74, Summer 2000, pp. 237–266) or ‘The Emer-
gence of the Swiss Tax Haven, 1816–1914’, Business History Review (vol.
95, Summer 2021, pp. 1–20, https://doi.org/10.1017/S00076805200
00914). He is currently writing a book on Switzerland’s role as a major
player in the international tax evasion market that developed between the
beginning of the nineteenth century and the First World War. He has
also directed several doctoral theses in these fields, which were subse-
quently published, including Yves Sancey, Quand les banquiers font la loi.
Aux sources de l’autorégulation bancaire en Suisse et en Angleterre de 1914
aux années 1950 (Lausanne: 2015) or Christophe Farquet, La défense du
paradis fiscal suisse avant la Seconde Guerre mondiale: une histoire inter-
nationale (Neuchâtel: 2016). He has recently led research project funded
xiii
xiv EDITORS AND CONTRIBUTORS
by the Swiss National Science Foundation entitled ‘The Antechambers of

H(e)aven? Tax Laws and Tax Practices of the Swiss Cantons 1870–1974’,
which focuses on the history of taxation in the Swiss cantons and the
role of their tax competition in the birth and development of the Swiss
offshore centre. He is also a member of the federal commission in charge
of the publication of the Diplomatic Documents of Switzerland series.
Finally, he is one of the founders, in 2002, of one of the most influential
NGOs on tax policy at the international level, the Tax Justice Network
(TJN).
Hadrien Buclin is a part-time Lecturer at the University of Fribourg,

Switzerland, and, since June 2023, researcher at the Institute of Political
Studies of the University of Lausanne. He was also, in 2017–2019, a
visiting research fellow at Paris 1 University and, in 2019–2022, a senior
researcher at the History Department of the University of Lausanne. His
research focuses on the history of Switzerland in the twentieth century.
He is the author of Les intellectuels de gauche: critique et consensus dans
la Suisse d’après-guerre (1945–1968) (Lausanne: 2019). He is currently
writing a book on Swiss social democracy, economic crises, and the rise of
neoliberalism in the 1970s to 1990s. More recently, he has developed a
field of research devoted to the history of taxation in Switzerland; he co-
edited on this subject with Sébastien Guex: La fiscalité directe des cantons
suisses. Législations et pratiques aux XIXe et XXe siècles (Basel: 2022) and
wrote a chapter in this book on the introduction of wealth tax and tax
evasion in Geneva after the First World War.
Contributors
Vivien Ballenegger is a Ph.D. candidate at the University of Lausanne.

His dissertation focuses on the history of taxation in the Swiss cantons
of Bern and Vaud between the mid-nineteenth and mid-twentieth
centuries. His article ‘Imposer les successions pour réduire les inégal-
ités? Le cas du canton de Berne, 1852–1919’ (2021) presents the history
of inheritance taxation in the canton of Bern and discusses the social and
political origins of its main reforms. His other article, ‘Les stratégies du
patronat bernois pour limiter la contribution fiscale des sociétés, de 1918
à 1945’ (2022), describes the broad fiscal resistance and offensive of the
Bernese employers, which resulted in the reduction of their tax burden.
EDITORS AND CONTRIBUTORS xv
Tijn van Beurden is a private scholar. His research subjects are the history
of tax avoidance and tax havens. He obtained his Ph.D. degree from
the University of Amsterdam in 2018, on a thesis titled The Curaçao
Offshore: Origin, Growth and Decline of a Tax Haven, 1951–2013. This
thesis demonstrates that the offshore activities on Curaçao were an attrac-
tive but vulnerable source of government income. His last publication
was together with J. Jonker: ‘A perfect symbiosis: Curaçao, the Nether-
lands and financial offshore services, 1951–2013’ in the Financial History
Review of 14 January 2021. This article demonstrates how Curaçao
offshore was prompted by Dutch initiatives, boosted by Dutch multi-
nationals and service providers, and supported by Dutch foreign policy
throughout.
Marc Buggeln is Assistant Professor at the Friedrich-Meinecke-Institute
at the Free University Berlin and Privatdozent at the History Depart-
ment at Humboldt-Universität zu Berlin. From 1 October 2021 to
30 September 2022, he was substituting this professorship for Social,
Economic, and Technological History at Helmut Schmidt Univer-
sity/University of the Armed Forces in Hamburg. His main research
interests are German and European history in the nineteenth and twen-
tieth centuries, concentration camps, (forced) labour, National Socialism,
social inequality, tax and budget policy, and governmentality. His habil-
itation with the title The Promise of Equality. Progressive Taxation and
the Reduction of Social Inequality since 1871 was published by Suhrkamp
in September 2022. He is the editor of The Political Economy of Public
Finance (CUP) with Martin Daunton and Alexander Nützenadel.
Sacha Dray is a Ph.D. candidate in economics at the London School of
Economics. He holds a master’s degree in Economics from Sciences Po
and LSE, a bachelor’s degree in Economics from Sciences Po, and a B.Sc.
in Mathematics from Sorbonne UPMC University. His research interests
are in economic policy and political economy around the drivers of health
and wealth inequality. Prior to his Ph.D., Sacha worked as a consultant
for The World Bank and the Asian Development Bank.
Nasrin Düll is a student of history, sociology, and political science at the
Goethe University Frankfurt. As part of her work on the research project
‘International Cultural History of Tax Morale’ by Prof. Korinna Schön-
härl, she has been studying tax education programmes and tax discourses
in the United States since the 1940s.
xvi EDITORS AND CONTRIBUTORS
Fabio Ecca obtained the title of Ph.D. at the University of Rome, ‘Tor
Vergata’, in 2016. Ecca deals with the relationship between the public
sector and the private sector during exceptional events. In recent years,
his research has mainly concerned the analysis of the contracts stipulated
during and after WWI. He has numerous publications on this subject,
including Lucri di guerra. Le forniture di armi e munizioni e i ‘pescecani
di guerra’ in Italia (1914–1922). Recently he has been dealing with
the use of satirical and caricatured drawing to denounce economic and
social distortions (for example: ‘“Pescecanismo”. Aspects of the Crisis of
the Italian State in Dealing with War Profiteering 1915–1922’, Memoria
e Ricerca, 2020/1). Fabio Ecca is currently Lecturer in Contemporary
History at the Department of Humanities of the Roma Tre University.
Chloe Fyfe is a doctoral researcher at the University of Glasgow. She is
currently carrying out an interdisciplinary exploration of the impact that
tax havens have on the art market—with a specific focus on tax evasion
and money laundering in the post-Brexit climate. Luxury freeports
and the development of the freeport mechanism from antiquity to the
contemporary period, play a central role in this research. Her recent publi-
cations include, ‘The Legacy of Livorno: Trade, Corruption and Religion
in the development of the Freeport Mechanism’, for the 8th Annual Days
of Justinian Journal for the Institute of National History, Skopje.
Thibaud Giddey is a lecturer at the University of Lausanne and an asso-
ciated researcher at the University of Oxford. He obtained his Ph.D. in
arts (history) at the University of Lausanne in 2017. He was a visiting
research fellow at KU Leuven (2013), City University London (2014),
and Uppsala University (2019). His research interests include the history
of banking supervision, financial scandals, the development of political
and financial elites, the history of white-collar crime and of lawyers as
business professionals, and finally, the development of taxation and tax-
induced mobility. His book, Histoire de la régulation des banques en
Suisse (1914–1972) (Geneva: 2019), deals with the evolution of banking
supervision in Switzerland during the twentieth century. A second co-
authored book with Eiji Hotori and Mikael Wendschlag, Formalization
of Banking supervision (Singapore: 2022), offers a cross-country and
historical perspective on the adoption of formal financial supervision.
James Hollis is a D.Phil. candidate in history at Brasenose College,
Oxford, and a former holder of the Walter Scott studentship in the
EDITORS AND CONTRIBUTORS xvii
global history of capitalism. He is the author of ‘Union Cold Storage

and the Birth of Multinational Tax Planning, 1897–1922’ (University
of Oxford Case Studies in the Global History of Capitalism, No. 9,
2019); the co-author, with Christopher McKenna, of ‘The Emergence
of the Offshore Economy, 1914–1939’, in Capitalism’s Hidden Worlds,
edited by Kenneth Lipartito and Lisa Jacobson (Philadelphia: Univer-
sity of Pennsylvania Press, 2020); and the editor and translator of Alain
Vernay’s classic 1968 work Tax Havens (Nottingham: Edward Ludlam,
2021). A qualified attorney, James has also published various technical
articles on aspects of corporate taxation.
Sébastien Laffitte is a post-doctoral student in economics at the Univer-
sité Libre de Bruxelles. He obtained his Ph.D. from the ENS Paris-Saclay
(Université Paris-Saclay) in 2022. His research is focused on international
public finance. He is particularly interested in the taxation of multina-
tional enterprises and in the role of tax havens in today’s globalised world.
He participated in the French Council of Economic Analysis (CAE)’s
works on evaluating the reform of international taxation. His recent
work on the subject has focused on the determinants of tax havens,
their role in shaping multinational firms’ decisions, and on evaluating
the impact of reforms of the international corporate tax system. He has
also published papers that study the link between multinational banks’
geographic expansion and their risk.
Arjan Lejour is Professor of Taxation and Public Finance at Tilburg
University and a project leader in the Public Finance Sector of the Nether-
lands Bureau for Economic Policy Analysis (CPB). Between 2011 and
2018, he was the programme leader in taxation at CPB and he has
previously been a senior researcher in international economics. Lejour
is an expert in (international) business taxation, tax avoidance, and tax
evasion. His latest publication on ‘The Immeasurable Gains of Dutch
Shell Companies in International Tax and Public Finance’ (International
Tax and Public Finance) focused on the international tax avoidance of
multinational firms via the Netherlands. Last year he also wrote a discus-
sion paper, ‘Offshore Tax Evasion and Wealth Inequality: Evidence from
a Tax Amnesty in the Netherlands’ on the offshore wealth of Dutch
households and the incentives of voluntary disclosure schemes.
Sylvain Praz is currently researching for a Ph.D. in history at the
University of Lausanne, on the tax history of the cantons of Zurich and
xviii EDITORS AND CONTRIBUTORS
Sankt-Gallen between 1860 and 1960. He has published about the taxa-
tion of small taxpayers ‘Sujétion fiscale et pratique d’imposition à l’égard
des petits contribuables (Zurich 1870–1952)’ In: Sébastien Guex, Gisela
Hürlimann, Matthieu Leimgruber (dir.), Steuern und Ungleichheit =
Fiscalité et inégalités, Zurich, Chronos, 2021; and about the introduction
of corporate tax laws in Switzerland ‘Entre justice fiscale et concurrence.
La fiscalité des sociétés anonymes à Zurich et Saint-Gall (années 1860–
Première Guerre mondiale)’ In: Sébastien Guex, Hadrien Buclin (éds.),
La fiscalité directe des catons suisses. Législations et pratiques aux XIXe
et XXe siècles = Die direkten Steuern in den Schweizer Kantonen. Geset-
zgebung und Praxis im 19. Und 20. Jahrhundert, Bâle, Schwabe Verlag,
2022. A publication with Aniko Fehr (Lausanne) about tax amnesties in
Switzerland (1933–1968), resulting from contribution to a colloquium
about tax resistance (Frankfurt, March 2020), is under way.
Isabelle Rabault-Mazières is Associate Professor at Paris 1 Panthéon—
Sorbonne University and a member of the Centre d’histoire du XIXe
siècle/ISOR. She is interested in economic and financial issues from a
cultural and social perspective. In ‘“Mal absolu” ou “rédempteur du
Peuple”? Le crédit, la dette et l’usurier dans la France du XIXe siècle’,
The Tocqueville Review/La Revue Tocqueville, Vol. XL, n° 2, 2019, she
has focused on social representations of credit and debt in nineteenth
century France.
She is currently working on the capital levy tax returns of Parisians in
1945. In ‘La justice fiscale au sortir de la guerre: l’impôt de solidarité
nationale de 1945’, In: Emmanuel De Crouy-Chanel, Cédric Glineur,
Céline Husson-Rochcongar (ed.), La Justice fiscale (X e –XXI e siècles),
Bruxelles, Bruylant Édition, 2020, she confronts the intentions of tax
justice at the heart of the 1945 capital levy in France with the files of
Parisian taxpayers.
Nadya Melina Ramírez Lugo studied history, cultural anthropology,
theology, and Spanish at the Johannes Gutenberg University Mainz. As
part of her collaboration on Prof. Korinna Schönhärl’s research project
‘International Cultural History of Tax Morale’, she studies Spain’s public
discourse on tax morale, tax education programmes, and tax reforms
mainly since the Transition. Other research interests include colonial
history in Latin America and the cultural and social history of twentieth-
century Spain.
EDITORS AND CONTRIBUTORS xix
Korinna Schönhärl is Professor of Modern History at the University of

Paderborn. Her current research project, ‘International Cultural History
of Tax Morale’, compares discourses on tax-paying behaviour in Western
Germany, Spain, and the USA after 1940. Schönhärl’s post-doctoral thesis
was on European investment in Greece in the nineteenth century (Euro-
pean Investment in Greece in the Nineteenth Century, New York: 2020).
She holds a Ph.D. from Goethe University Frankfurt (Knowledge and
Visions. Politics and Theory of the Economists Around the Poet Stefan
George, Berlin: 2009). Further research foci are the history of economic
thought, the history of risk management, moral economics, postcolonial
history, and historiographic methodology.
Béatrice Touchelay is Professor of Contemporary History at the Univer-
sity of Lille and attached to the IRHiS UMR CNRS 8529 laboratory since
2011. Her research focuses on two instruments of state intervention in
France, Europe, and colonised territories (statistics, taxes), and on their
bias. Her research also concerns more broadly the economic and social
transformations of contemporary societies.
Of her last two publications, one deals with the practices of state
control over the French banking system after the nationalisations of
the Liberation (I. Chambost and B. Touchelay, ‘Les figures de l’État-
actionnaire: quand l’État devient banquier’, in ‘Les figures de l’État
actionnaire’, Hadrien Coutant, Scott Viallet-Thévenin (ed.), Revue de la
Régulation, juillet 2021 and, with Jean-Luc Mastin (ed.), Des banques
sous surveillance? Pour une histoire du contrôle bancaire (XIX e s.–début
XXI e s., Villeneuve d’Ascq, Presses universitaires du Septentrion, being
published 2022) and fraud, while the other presents and comments on
various papers at the colloquium on fraud that she organised in Paris in
2017 (B. Touchelay (ed.), Fraude, Frontières et Territoires, Comité pour
l’histoire économique et financière de la France-IGPDE, 2020).
Simon Watteyne is an FNRS post-doctoral researcher at the Université
libre de Bruxelles and is currently writing a book on the international
negotiations between British, American, Dutch, Swiss, German, and
French central and private banks to stabilise the Belgian currency in
the mid-twenties. He was previously a junior research fellow and post-
doctoral researcher at Wolfson College (Oxford). He earned his Ph.D. in
history (La prédominance d’une fiscalité libérale en Belgique. Une histoire
politique (1847–1962)) at the Free University of Brussels in 2021 and he
xx EDITORS AND CONTRIBUTORS
is the author of Aux sources de l’impôt en Belgique. Une histoire de conflits

politiques 1830–1962 (CRISP, 2022).
He is also the author of several papers focusing on Belgian tax history:
‘La bataille des impôts du Parti Ouvrier Belge (1936–1938)’, Revue
Belge de Philologie et d’Histoire, 2 (2021) 461–496; ‘Le coût de la
première guerre scolaire et les débats des ‘Graux impôts’ (1878–1884)’,
Journal of Belgian History, 2 (2020) 34–60; ‘La révolution fiscale de la
Belgique martyre (1914–1920)’ In: Cédric Glineur, Emmanuel de Crouy-
Chanel et Céline Husson-Rochcongar, La justice fiscale (X e –XXI e siècles)
(Bruylant, 2020) 173–194.
Katia Weidenfeld is a professor of contemporary legal history at the
Ecole nationale des chartes (PSL University, Centre Jean Mabillon). Her
work focuses on the history of tax law in France in the contemporary
period. In this field, she recently directed and participated in a collective
work on the history of the tax return, from its first applications in the
eighteenth century to the introduction of the levy at source (Déclarez
vos revenus! Histoire et imaginaire d’un instrument fiscal, Paris: 2019),
and she also studied the claims of publicity in tax matters in the twen-
tieth century (‘La transparence fiscale. Genèse législative d’un mythe’, La
justice fiscale Xè-XXIè siècle, Brussels: 2020).
Mikael Wendschlag is a researcher and lecturer at Uppsala University,
Sweden. He received his Ph.D. in economics from Linköping University.
His research interests are international tax evasion, financial supervi-
sion and regulation, financial crises, economic crime, and central bank
history. He has conducted commissioned research for the Swedish Finan-
cial Supervisory Agency and the Swedish Riksbank. He has been a visiting
researcher at the Swedish House of Finance, the European Univer-
sity Institute in Florence, the Swedish Riksbank, and the Institute for
Economic and Business History Research at the Stockholm School of
Economics, Sweden. He has also worked as a research assistant at the
Swedish Institute for International Affairs. In 2020, he was awarded the
annual Hans Dahlborg award for research in banking and finance.
List of Figures
Fig. 2.1 The emergence of tax havens in the twentieth century

(Source Laffitte [2022]) 45
Fig. 2.2 Tax introduction and tax havens 48
Fig. 3.1 Evolution of the number of resident foreigners
benefiting from the ‘Foreigners’ Tax’ or the ‘forfait
fiscal’ (1918–1956) (Sources BGC, 8 November 1920,
p. 33; List of taxpayers subject to the Foreigners’
Tax, 1921–1947, Vaud Cantonal Archives (VCA),
Chavannes-près-Renens, K X a 174; Gubler 1949,
98; Letter from the Lausanne District Commission
to the FTA, 8 March 1950, Swiss Federal Archives,
Berne, E6302B#2003/1#521*; FTA, Monthly
report. Tax for national defence, 8th period. Canton
of Vaud, 7 May 1956, VCA, SB 163/26, p. 4. Share
of the canton’s population, calculated from figures
provided by Lorusso [1989, 25–27]) 58
Fig. 3.2 Tax revenues generated by the preferential tax regime
(Sources Accounts of the canton of Vaud, published in:
Compte rendu du Conseil d’Etat, 1918–1960) 59
Fig. 6.1 Swedish community in Switzerland, by region
(1941–2000) (Source Office fédéral de la statistique,
Recensement fédéral de la population) 123
xxi
xxii LIST OF FIGURES
Fig. 6.2 Distribution of Swedes in Swiss cantons by tax index,

1960–1990 (Sources Swedish population: Office fédéral
de la statistique, Recensement fédéral de la population;
Tax index: Steuerbelastung in der Schweiz/Charge
fiscale en Suisse, Eidg. Steuerverwaltung, Aministration
fédérale des contributions; Lump-sum taxation
for cantons [colour code]: 1964: Bericht über
die Veranlagung zur Pauschalsteuer gem. Art.
18 bis WSTB pro 12. Periode [Steuerjahre 1963
und 1964], 1973: Bulletin sténographique du
Conseil national, Réponse de Nello Celio à Motion
Reich, Pauschalsteuer Abschaffung, 04.06.1973,
pp. 450–451, 1983: [Bernasconi 1983, 90],
1999: Die Finanzdirektorenkonferenz [FDK] zur
Aufwandbesteuerung, 2009) 125
Fig. 6.3 Correlation between the density of Swedes and the level
of wealth in Swiss municipalities (1980) (Sources
Swedish population: Bundesamt für Statistik, Eidg.
Volkszählung 1980, Originalstand der Gemeinden und
der Staaten. Tax return index: Eidg. Steuerverwaltung
Steuererträge und Kopfquoten 1981/82) 130
Fig. 6.4 1964—lump-sum taxpayers established in Switzerland
by nationality (Source Swiss federal archives,
E6302B#2003/1#530*, Eidgenössische
Steuerverwaltung, Bericht über die Veranlagung
zur Pauschalsteuer gem. Art. 18 bis WSTB pro 12.
Periode [Steuerjahre 1963 und 1964], by Max Hunziker) 131
Fig. 7.1 Average statutory tax rates for selected country groups
in 2000 and 2020 (Source OECD tax database. Averages
are unweighted) 141
Fig. 7.2 The size of outward FDI positions in 2018 (billion US
dollars) (Source IMF CDIS database) 149
Fig. 7.3 The shares of country groups in foreign direct
investment positions, 2009 and 2019 (Source IMF
CDIS database) 149
Fig. 7.4 International payments for the use of intellectual
property (IP) rights (Source World Development
Indicators from the World Bank) 151
LIST OF FIGURES xxiii
Fig. 10.1 An estimation of tax evasion on wealth based

on inventories (1860–1918) (Sources 1860–1868:
“Bericht des Regierungsrathes zu dem Gesetzesentwurf
betreffend die Vermögens-, Einkommens- und
Aktivbürgersteuer”, 28.09.1869, in: Amtsblatt des
Kantons Zürich [Amtsblatt], p. 1676; 1869–1899:
Bericht über die Finanzlage des Kantons Zürich,
28 November 1901, pp. 71–73, Schweizerisches
Sozialarchiv [SozA], Zurich, KS 336/28; 1900–1918:
Rechenschafts-Bericht des Regierungsrates an den
Zürcherischen Kantonsrat [Rechenschaftsbericht],
various years) 203
Fig. 10.2 An estimation of tax evasion on wealth and revenue
based on inventories (1923–1945) (Sources
Geschäftsbericht Stadtrat, 1923–1945) 213
Fig. 12.1 Tax delinquency rate (Notes This figure shows
the average tax delinquency rate at the city level,
broken down by cities above or below the median tax
delinquency rate in 1933) 247
Fig. 12.2 Housing princes (Notes This figure shows
the permit value index, broken down by cities
above or below the median tax delinquency rate
in 1933. Permit value index is a measure of the average
cost per family housing unit as constructed
by the Bureau of Labor Statistics, presented as an index,
with 1930 as the base year. It is used as a proxy
for house prices) 248
Fig. 12.3 Property value per capita (Notes This figure shows
the average taxable property value per capita, broken
down by cities above or below the median tax
delinquency rate in 1933. Property value is defined
as the annual value of property assessed for the purpose
of property tax) 249
Fig. 12.4 Rate of property tax (Notes This figure shows
the average tax rate on property applied by cities,
Fig. 12.5 Housing permits (Notes This figure shows the average
number of housing permits, broken down by cities
above or below the median tax delinquency rate
in 1933. The number of permits is a proxy for residential
construction activity) 250
xxiv LIST OF FIGURES
Fig. 12.6 Municipal Spending (Notes This figure shows

the average total municipal spending per capita,
Fig. 12.7 Municipal revenue (Notes This figure shows the average
total municipal revenue per capita from all sources,
Fig. 12.8 Municipal Revenue from Property Tax (Notes
This figure shows the average municipal revenue
per capita from property tax, broken down by cities
above or below the median tax delinquency rate in 1933) 252
Fig. 12.9 Municipal Debt (Notes This figure shows the average
amount of debt per capita, broken down by cities
above or below the median tax delinquency rate in 1933) 252
Fig. 12.10 Trends in Municipal Finances and Housing Markets
(Notes See main text for details) 259
Map 6.1 Swedes in Switzerland: communal distribution (1980)

(Source Bundesamt für Statistik, Eidg. Volkszählung
1980, Originalstand der Gemeinden und der Staaten) 127
Map 6.2 Swedes in Lake Geneva Region: communal distribution
(1980) (Source Bundesamt für Statistik, Eidg.
Volkszählung 1980, Originalstand der Gemeinden und
der Staaten) 128
List of Tables
Table 6.1 Swedish emigration and immigration

to and from Switzerland, 1971–1981 120
Table 6.2 Swedish emigrants with Riksbank permission to move
more than one million SEK out of the country, number,
per cent and country of destination, 1964–1984 122
Table 6.3 Socio-economic profile of Swedes in Switzerland 1977
(per title) (n = 192) 133
Table 7.1 Changes in tax characteristics between 2009 and 2017
(averages for 108 countries) 147
Table 7.2 Impact of tax havens and conduit countries on tax
avoidance 152
Table 9.1 Corrected tax returns and additional revenues
from Prussian income tax, 1900–1908 185
Table 9.2 Top Rates of Income Tax 1917/18 (in %) 194
Table 10.1 Indirect estimations of wealth that should have been
taxed (millions CHF) 204
Table 10.2 Wealth discovered through inventories according
to the wealth level of taxation (1890–1896) 205
Table 10.3 The proportion of taxpayers who were caught evading
taxes in the jurisdiction of the city of Zurich, according
to the level of taxable wealth (1896–1916) 208
Table 10.4 The taxpayers who used the tax amnesty in 1936,
according to the level of taxable income 214
Table 11.1 Summary diagram of the revenue from taxes on war
profits 235
xxv
xxvi LIST OF TABLES
Table 11.2 Summary diagram of the application of the reduction

coefficients for comparability between the different years 236
Table 12.1 Summary statistics 246
Table 12.2 Determinants of tax delinquency 253
Table 12.3 Consequences of pas delinquency 255
CHAPTER 1
Introduction. “Low-Tax Predators” Rather

Than “Tax Havens”: New Perspectives
on the History of the International Tax
Evasion and Avoidance Market
Sébastien Guex
The numbers are astronomical. According to a study presented in

November 2021 by the most reliable NGO on international taxation, the
Tax Justice Network, “multinational corporations are shifting US$1.19
trillion worth of profit into tax havens each year, causing governments
around the world to lose US$312 billion a year in direct tax revenue”
I am very grateful to Janick Marina Schaufelbuehl for her valuable assistance in

writing this introduction.
S. Guex (B)
Department of History, University of Lausanne, Lausanne, Switzerland
e-mail: sebastien.guex@unil.ch
© The Author(s), under exclusive license to Springer Nature 1

Switzerland AG 2023
S. Guex and H. Buclin (eds.), Tax Evasion and Tax Havens since
the Nineteenth Century, https://doi.org/10.1007/978-3-031-18119-1_1
2 S. GUEX
(TJN 2021: 30). As for the financial wealth owned by the rich or super-
rich individuals and hidden from the tax authorities of their country of
origin in tax havens, it amounts to about $10’000 billion, which equals
the combined GDP of Germany, the UK, France and the Netherlands.
This means there is an additional loss of revenue of about $171 billion,
which brings the total to $483 billion, a sum equivalent to the tax revenue
of a country like Spain (TJN 2021: 42 and 46–53). But these sums,
although gigantic, represent only a fraction of the total amount of tax
evasion and avoidance. To name only one of these estimations’ short-
comings: they do not take into account the non-financial assets (such as
real estate, gold, cultural goods, etc.) which are evaded from taxation by
wealthy individuals and which are three to four times higher than the
financial assets (TJN 2021: 47).
These figures alone show that this book deals with phenomena that
play a major role in the functioning of contemporary capitalism: tax
evasion and tax avoidance by the possessing classes, especially when this
practice that can be called escape from taxes or tax non-compliance is
performed on an international scale, i.e., by resorting to tax havens.
However, these phenomena are neither new nor even recent. As several
contributions in this book show, they have a long history that reaches
back well into the nineteenth century.
In this article, it is not possible to trace even the lineaments of this
history, especially since it is intricate and complex. I will content myself
with presenting some considerations on aspects that, from a method-
ological point of view, in particular, seem particularly important to me.
I do not claim to offer anything like a comprehensive reflection on these
subjects, since the current state of knowledge does not allow for this. My
hope is to encourage new research on these issues, which will undoubtedly
correct in part what is going to be presented.
A History Still in Its Infancy

Since the 1990s, the literature devoted to international tax evasion and
avoidance, and in particular to the misnamed—I will come back to
this problem—“tax havens” has grown almost exponentially. In their
2010 study, which to my knowledge is the best overall analysis of these
phenomena, Ronen Palan, Richard Murphy and Christian Chavagneux
note that there is “a veritable explosion of new information” (Palan et al.
2010: 4). If we limit ourselves to academic literature, a search using the
1 INTRODUCTION. “LOW-TAX PREDATORS” RATHER THAN … 3
keyword “tax haven” and including only doctoral theses listed in the
“Proquest Dissertations & Theses” database supports this observation:
since 1990, nearly 750 of these works have been devoted to the issue
of tax havens, or significantly address it, and their number has roughly
doubled from one decade to the next.1
There is therefore an impressive literature, including academic liter-
ature, on the field of tax evasion, tax avoidance and tax havens. But,
within this vast literature, the number of works that have taken an
in-depth and problematized interest in the history of these phenomena,
in particular, in their distant history, remains very limited. For the most
part, and again to the best of my knowledge, these are studies by Piciotto
(1992), Hampton (1996), Palan (2003), Godefroy and Lascoumes
(2004), Rawlings (2004), Spoerer (2004), Palan et al. (2010), Freyer
and Morriss (2013), Farquet (2016), Ogle (2017, 2020), Hollis and
McKenna (2020) and Guex (2021).
The paradox is therefore striking: There exists a very abundant litera-
ture on the issue, but it is very poor on the historical level. This obser-
vation is shared by many authors. In 2004, Gregory Rawlings deplored
that this literature was characterized by a “lack of historical perspec-
tive”, with the result that “tax havens are presented as new, sudden and
aberrant intrusions into the world’s financial markets” (Rawlings 2004:
326). A dozen years later, Vanessa Ogle noted that “the archivally based
literature on tax havens and offshore jurisdictions is extremely scarce”
(Ogle 2017: 1437). Finally, James Hollis and Christopher McKenna
have recently in turn highlighted “the comparative scarcity” of historical
research, pointing out that this scarcity “is certainly surprising” (Hollis
and McKenna 2020: 158).
There is also a second problem. It is true that the literature on tax
evasion and avoidance and/or tax havens often briefly touches on the
history of these phenomena. However, in these cases, the studies are
almost always characterized by very serious shortcomings, including those
produced by academia. They generally don’t follow basic methodological
rules required by historical research and often are surprisingly superficial.
What makes matters worse is that they tend to peddle and propagate many
fictions or falsifications—terms which seem to me more appropriate than
those of myths or legends which are generally used—in part fabricated by
1 The search was performed with the single keyword “tax haven”; https://www.pro
quest.com/pqdtglobal/advanced/empty?accountid=10226 Accessed 29 April 2022.
4 S. GUEX
the promoters and defenders of tax evasion and tax havens themselves.
Sometimes these studies even add new fictions or falsifications, such as a
recent study that claimed, without any foundation, that at the beginning
of the twentieth century, in Switzerland, tax competition between cantons
was imported from the United States and that the tax privileges granted
to holding companies were copied from England (Tobler 2019: 56). In
short, as Ronen Palan noted in 2009, “the history of tax havens is riddled
with myths and legends” (Palan 2009: 2).
As a result, despite the existence of a vast literature, not only the under-
standing but also the simple knowledge of the origins and evolution of
tax evasion, avoidance and havens remains very incomplete and approxi-
mate. How to explain such a paradox? It seems to me that three avenues
of reflection lead to the beginning of an answer. First, this literature is
almost entirely produced by political scientists, lawyers, economists, tax
experts and journalists, that is to say, by categories of researchers who
are essentially interested in the present or the very recent past. Moreover,
a significant part of them is more or less directly linked to the different
actors of the international tax evasion and avoidance market. Thus, one
of the first and most influential comprehensive studies of tax havens,
published in 1971 by The Economist Intelligence Unit and written by
two tax experts (Doggart and Voûte 1971), was in fact a kind of guide
for wealthy people who wanted to make up their own minds about
which haven or havens best suited their situation and needs. In a slightly
different form, it was reprinted and translated several times from 1975
onwards (Doggart 1975; Brittain-Catlin 2010). In the eyes of this group
of authors, history is therefore of little interest or, at best, of marginal or
anecdotal interest, as Vanessa Ogle noted: “The vast majority of works on
tax havens is by political scientists or writers for a broader, popular audi-
ence. In this literature, historical developments are normally addressed as
background introduction” (Ogle 2020: 218).
The second avenue of reflection is that a considerable part of this liter-
ature favours an approach to tax non-compliance that is not only centred
on the individual but also naturalizes or essentializes this phenomenon,
and therefore tends to be ahistorical. Indeed, it sees tax evasion and
avoidance as the result of an innate individual disposition, and thus as an
immutable or timeless phenomenon because it is rooted in the “nature”
or “essence” of human beings (Leroy 2007: 98). For example, a tax
manual published in 2011 states in a typical fashion that “Tax non-
compliance is as old as the world” (Alink and van Kommer 2011: 163).
In 2013, the tax expert of the most influential Swiss daily newspaper, the
Neue Zürcher Zeitung, claimed: “Tax evasion […] is a constant of human
nature”.2 And finally, the axiom political scientist Sven Steinmo intro-
duced in a recent book on tax non-compliance is: “No one likes to pay
taxes” (Steinmo 2018: 5).
It should be noted that this approach is part of a long tradition:
“...there is hardly any other one thing which human nature so much
dislikes to do as to pay taxes”, the American economist David Ames Wells
argued more than a century ago (Wells 1900: 515). For his part, since the
1870s, the most influential French economist of the time, Paul Leroy-
Beaulieu, has repeated over and over again that “given human nature”
there is a “universal tendency to defraud the state” (Leroy-Beaulieu 1879:
209; see also 260). And in 1911, a jurist from the French tax administra-
tion began a study of tax evasion with these words: “…man has a natural
tendency […] to consider taxes as a prejudice caused to him, rather than
as a just contribution to public expenditure; the individual has always
preferred his own interest to that of the community” (Garnier 1911: 3–
4). Such a notion, like any naturalizing or absolutizing understanding,
tends to be ahistorical, not to say antihistorical, since it considers escape
from taxes as a purely individual phenomenon that is supposed to occur at
all times and in all places, and not as a social phenomenon, which is born
from social relations and evolves according to changes in these relations,
i.e., according to circumstances. The least that can be said is that it does
not encourage a rigorous and meticulous examination of the appearance,
evolution, expansion or decline of tax evasion and/or avoidance, in short,
of its concrete history.
However, and this is the third avenue of reflection, what has just been
said does not offer a sufficient explanation of the shortcomings of liter-
ature on tax evasion, tax avoidance and tax havens. There remains the
fact that, apart from a small number of historians, many of whom have
been mentioned above, historians themselves have hardly delved into the
history of tax evasion and avoidance over the past two centuries, and even
less into that of tax havens. They therefore share some responsibility for
the flaws of historical research in this field. Why is there a certain lack
of interest in this subject? It seems to me that part of the reasons come
from the major decline that socio-economic history has suffered within
2 Neue Zürcher Zeitung, 6 April 2013.

6 S. GUEX
academic research for three or four decades and until recently. All the
more so since this decline has been to the benefit, on the one hand, of
post-modernist cultural history and, on the other, of “historical economy”
(Gervais 2019: 26; see also Margairaz 2013: 81). The latter is largely
dominated by economists of the classical and neoclassical school, who are
generally more concerned—in the field of taxation as in others (Vlcek
2008: 34–41)—with forcing reality into their highly formalized models
than with confronting reality itself. Secondly, we must, however, also insist
on the fact that any in-depth and rigorous historical exploration in the
highly sensitive field of escape from taxes runs a serious danger, one that
may discourage many vocations. This danger is that of encountering what
two researchers working on the role of the State of Malta in the interna-
tional tax evasion and avoidance market have called the “conspiracy of
silence” (Fabri and Baldacchino 1999: 157), that is to say, the profound
hostility of the powerful actors, promoters and defenders of this market,
and the multiple, often insurmountable, obstacles that they oppose to any
scientific historical investigation.
To conclude this brief historiographical discussion, it is time to specify
not only the ambitions but also the limits of the present book. Overall,
its objective is to contribute to fill some of the gaps in historical research
mentioned above. In other words, it aims to improve our knowledge and
understanding of the history of tax evasion and avoidance, especially when
these are practiced internationally, using states or jurisdictions specifically
set up for this purpose: tax havens. There are some limitations, of which
the first is spatial. The contributions gathered here focus strongly on
Western Europe and only marginally consider certain other continents,
while completely ignoring some. The second limitation is temporal. If the
book—and this is one of its main contributions—goes back a long way in
history, to the middle of the nineteenth century, it does not deal much
with the very important developments that have occurred since the 2000s
(see, however, the chapters by Lejour and Fyfe in this book). The third
limitation is thematic. Going beyond the framework set at the outset of
this book, a series of major issues—for example, the effects of tax evasion,
avoidance and havens on the globalization of the economy, on the evolu-
tion of taxation on the worldwide scale or on the development of social
inequalities—are not taken into account, or only marginally.
A New Periodization and Its Consequences

In the literature, that to date has examined the birth and evolution of the
international tax evasion and avoidance market, and thus of tax havens,
there is a consensus on the main phases of this history. The phenomenon
truly emerged during the interwar period, grew significantly during the
decades following the Second World War, and soared in the 1970s.
Vanessa Ogle deserves the credit for having offered the most synthetic
summary on this subject. She writes: “An assessment of its historical scale
and scope reveals that there were three distinct phases in its development.
During the first phase, which lasted from roughly the 1920s to World War
II, the offshore world, and tax havens in particular, emerged on a mostly
moderate scale. The second phase, which lasted from 1945 to 1975, saw
the significant growth of the offshore world. A third stage then began in
the 1970s, which was marked by [a] dramatic expansion…” (Ogle 2017:
1436). Scholars may differ slightly on the temporal boundaries of the
second and third stages, but, along with Ogle, they are unanimous on
one point: the true emergence of the phenomenon occurred after World
War I, in the 1920s or 1930s (Picciotto 1992: 22, 118; Hampton 1996:
17, 36; McCann 2006: 20; Sharman 2006: 22; Godefroy and Lascoumes
2010: 26–27; Palan et al. 2010: 107–118; Farquet 2016: 26–27, 75;
Keen and Slemrod 2021: 258). In other words, they agree, as histo-
rian Mark Spoerer has forcefully argued, that “…there is no evidence that
tax competition occurred at the international level before World War I”
(Spoerer 2004: 192; see also Farquet 2018: 52–53).
The question needs to be studied much more thoroughly, but there
is already sufficient evidence that this periodization does not correspond
to reality in one respect. The process that saw the emergence of the first
tax havens actually began already in the second half of the nineteenth
century and led to serious international tax competition even before the
First World War. Let us briefly review the main clues that support this
revised periodisation.
1. From the second half of the nineteenth century, at the insti-

gation of tourism and banking circles interested in transforming
Switzerland into a privileged resort destination for international
high society as well as in developing wealth management activi-
ties, several cantons—Geneva, Vaud, Neuchâtel, Grisons, Ticino and
Lucerne—adopted a series of tax provisions. These provisions almost
8 S. GUEX
totally exempted a certain category of residents from taxation: the

wealthy rentiers from neighbouring countries or even from over-
seas who came to reside, for a long time or even permanently, in
these cantons (Guex 2021; Ballenegger and Giddey, Wendschlag
in this volume). It is highly probable—but this would have to be
confirmed by further research—that in Germany and, perhaps, in
France, some tourism regions have obtained similar tax privileges in
order to compete with these Swiss cantons.3
2. As early as the last decades of the nineteenth century, the Swiss and
Belgian banking circles entered into a lively competition to attract—
with undeniable success—the financial wealth of the possessing
classes wishing to escape various tax measures affecting them in
France and, to a lesser extent, in Germany and other countries
(Guex 2021; Watteyne in this volume). In order to capture this
capital, Swiss and Belgian banks have already progressively put into
place certain tools and practices intended to actively incite and assist
the capital’s owners to escape tax authorities, devices which would
make headlines from the 1970s onwards: for example, the intensive
canvassing of potential clients by clandestine bank representatives,
whom a French jurist of the time called “tax evasion clerks [commis-
voyageurs de la fraude]” (Girard 1916: 44); the use of numbered
accounts, false names and straw men to best conceal the identity of
the true owners of the deposits made with the banks; or the joint
account, a tailor-made instrument to evade inheritance tax. And
when the French state attempted to hinder this activity by, among
other things, asking the Swiss and Belgian governments in 1907 to
sign treaties that would introduce the automatic exchange of tax
information, the Swiss and Belgian not only flatly refused but even
publicly guaranteed to categorically respect banking secrecy vis-à-vis
foreign tax authorities, a fact which is crucial (Farquet 2016: 49–
58; Watteyne in this volume). In both countries, the development
and defence of this strategy of international tax competition has thus
become a position openly adopted by the State.
3 See Neue Zürcher Zeitung, 17 December 1869, Gazette de Lausanne, 27 December

1897 and New York Times, 9 December 1900.
Banks in other countries—not only the United Kingdom, in

particular, but also in Germany, Luxembourg and probably the
Netherlands and Spain—have also tried to compete in this market
segment (Guex 2021: 13). Why and to what extent have they done
so? What means did they use and with what success? Unfortunately,
there is still so little research on this history that it is not possible to
give even an approximate answer to these questions.
3. In the decades immediately preceding the First World War, compe-

tition also developed between different states or jurisdictions that
sought to attract the headquarters of large corporations to their
respective territories through the granting of tax privileges. As this
competition is even less known than the competition for the wealth
of individuals, there are considerably more unanswered questions
about it. Did the US states of New Jersey and Delaware play a
pioneering role in this respect, as a large part of the literature claims,
but without being truly convincing (Guex 2021: 19–20)? Were the
Netherlands and the United Kingdom already in the game, the latter
particularly relying on Jersey and Guernsey (Palan et al. 2010: 110;
House of Commons 1906: 131–132; Hollis in this volume)? This
may be the case.
4. What is certain is that, in 1903, inspired or stimulated by the
banking and industrial employers of the neighbouring Swiss canton
of Zurich, the authorities of the canton of Glarus adopted provi-
sions that virtually exempted the so-called “domicile” or “letterbox”
companies, such as holding companies, from taxation. The example
of Glarus was soon followed by the Swiss cantons of St. Gallen and
Schaffhausen, with quite some success (Guex 2021: 8–9). Again,
there are several indications that Belgium was Switzerland’s main
competitor in the efforts to induce foreign companies to establish an
administrative seat on its territory by granting tax privileges (Bitsch
1994; Watteyne in this volume).
5. Last but not least, even if this is again a very little researched subject,
it seems that the growing competition between banks in Europe in
the half-century preceding the First World War led British, French,
German, Belgian and Swiss authorities to begin to use taxation as
an instrument of competition with the aim of attracting certain
international financial operations to their financial centres, such as
10 S. GUEX
the issuance of loans, sales and purchases on the stock exchange,

the financing of large international trade, etc. The measures some-
times merely were meant to prevent competing financial centres to
attract these lucrative financial operations (Kaufmann 1914: 109;
Guex 2021: 9–10; Watteyne in this volume).
Despite many remaining uncertainties, it is therefore possible to affirm

that even before the First World War an international market for tax
evasion and avoidance services was formed. This is the term that seems
most precise, but I will henceforth use a slightly shorter and less cumber-
some expression, that of an international tax evasion and avoidance
market. This market involved actors, above all financial actors, from at
least six or seven countries. Two states that had already turned into actual
tax havens, Switzerland and Belgium, were particularly proactive.
Contemporaries were fully aware of the phenomenon. To cite just
one example, in a speech in the Belgian Parliament in August 1913, the
influential businessman and member of parliament Louis Franck charac-
terized Switzerland and Belgium as “oases in the midst of the invasive and
often aggressive taxation of the large neighbouring countries” (quoted by
Watteyne in this volume). He went on to point out, as did many other
deputies,4 the competition which existed between the two states in tax
matters. If the exact expression “tax haven” was not used on this occa-
sion, the terms used were strikingly close. Another unmistakable sign of
the establishment of such a market was the appearance of the first publica-
tions giving advice on the procedures that could be used internationally to
escape the taxes of one’s own state. They made comparisons between the
services provided in different states or jurisdictions, notably in Switzer-
land, Belgium or England, such as, for example, the degree of security
and discretion offered by the joint account system (see, for example,
Petitpas 1909; Chamber’s Journal 1910: 660–662; Depuichault 1911;
Sigrain 1914). These publications were actual precursors of the modern
guides to tax havens that proliferated from the 1970s onwards.
Based on these considerations, it is possible to propose a different
periodization from the one developed so far. It distinguishes four major
phases in the history of tax havens (see also Laffitte in this volume). The
4 See Annales parlementaires de Belgique—Chambre des Représentants, 7, 12, 13 and

19 August 1913: 2127, 2209, 2258 and 2326.
first, which ran from the last decades of the nineteenth century to the First
World War, saw the emergence of the first tax havens. During the second
period, the interwar years, the number of tax havens increased signifi-
cantly. After the Second World War and until the end of the 1960s—the
third phase—growth of tax havens accelerated before it skyrocketed from
the 1970s onwards, which can be considered the fourth phase. Perhaps
are we now in the process of moving into a fifth phase, characterized
by a slowdown in the growth of the international tax evasion and avoid-
ance market, its stagnation or perhaps even a certain decline, due to the
campaign against it led, especially, under the aegis of the OECD? It is too
early to say.
An important conclusion can be drawn from this new periodization.
When explaining tax evasion and avoidance, existing literature over-
whelmingly tends to attribute a decisive role to the height of the tax
burden. In other words, this almost ritualistic explanation—so much so
that it can be called a “vulgate” (Spire and Weidenfeld 2015: 7)—estab-
lishes a decisive, even exclusive and unidirectional causal link between the
degree of the tax burden and the extent of tax evasion and/or avoid-
ance: the higher the former, the greater the latter. This causal link was
even promoted to the status of a “law of increasing tax resistance” by
a German economist, Wilhelm Gerloff, in his influential Handbuch der
Finanzwissenschaft (Handbook of Financial Science) (Gerloff 1956: 630).
With regard more specifically to tax havens, this vulgate seems to be
confirmed by the periodization established so far, since their origin and
evolution are explained according to the following scheme: because of
the First World War, the levels of the taxes affecting the possessing classes
increased considerably. Consequently, these classes were said to have been
much more inclined than before the war to try to escape their tax obli-
gations, hence the appearance of the first tax havens during the interwar
period. The even higher levels established after the Second World War are
supposed to explain the multiplication of tax havens in the second half of
the twentieth century (Palan 2003: 5–6).
At this point, I should make a brief digression in order to point out that
the conception that there is a decisive causal link between the burden of
taxation and tax non-compliance has been elaborated and tirelessly prop-
agated for a very long time by the possessing classes themselves, as well
as by their representatives in the political, media and academic spheres.
There are several reasons for this, starting with the fact that it is linked
12 S. GUEX
to these classes’ ideology, which is mostly economically liberal and util-

itarian. But it should be noted that from their point of view, there is
also a crucial political and practical advantage to this notion. Indeed, if
the growth of taxes affecting the capitalist and wealthy circles automati-
cally translates into increased non-compliance of their tax obligations, the
most logical and simple conclusion is to tax them only lightly or not at all.
Numerous contributions in this book show that the issue of tax evasion,
tax avoidance and tax havens can be instrumentalized very effectively by
the ruling class, either to fight new taxes or tax increases or to obtain the
lowering or the abolition of existing taxes (Ballenegger; Watteyne; van
Beurden; Fyfe; Buggeln; Praz; Ecca; Dray; Weidenfeld; Hollis; Touchelay;
Rabault-Mazières). I will return to this aspect later.
But let us return to the explanatory scheme mentioned above. From
the second half of the nineteenth century to the First World War, although
the tax burden on the wealthy tended to increase, it remained relatively
low, in any case at levels very considerably lower—by five to ten or even
twenty times—than those which they would reach after the war. For
example, in ten countries participating in the First World War, the highest
nominal marginal income tax rate was, on average, around 3 per cent
between 1900 and 1913, a level ten to fifteen times lower than that which
it would reach in the same countries after the war. In France, this rate was
2 per cent on the eve of the world war, whereas it rose to between 20 per
cent and 72 per cent during the period of 1919–1929. In the United
Kingdom, this rate was 8.3 per cent in 1913 and was raised to 50–60 per
cent between 1919 and 1929. The highest nominal marginal rate of the
inheritance tax on direct descendants was, on average in 19 industrialized
countries, 3.3 per cent in 1880 and 4 per cent in 1913, a level four to five
times lower than in the 1920s. In short, as the study from which these
figures are taken summarizes, the tax burden on the rich before World
War I remained, if compared to that which has prevailed since, “at very
low levels” (Scheve and Stasavage 2016: 89; see also 54–113).
Yet this same period, 1850–1914, was characterized by tax evasion and
avoidance among the possessing classes of considerable, even massive,
magnitude, which in no way was significantly less than that reached
after the First World War (Becqué 1912: 310–317; Sabine 1966: 178–
181; Witt 1970: 371; Ardant 1972: 415–419; Colley 1998: 313–323;
Daunton 2001: 197; Morgan et al. 2009: 1365; Martin 2013: 27;
Ballenegger; Watteyne; Buggeln; Praz; Ecca; Hollis; Weidenfeld in the
present volume). Moreover, this escape from taxes was increasingly
accomplished through foreign jurisdictions and was thus accompanied,

as we have seen, by the emergence of an international tax evasion and
avoidance market, in other words, of the first tax havens.
In addition, there is another fact that invalidates the vulgate about the
history of tax havens. The proliferation of tax havens from the 1970s
onwards did not occur during a period of rising but falling taxes on the
possessing classes, as Ronen Palan convincingly points out (Palan 2003:
9–13). Between 1980 and 2013, the highest nominal marginal income
tax rate fell, on average in 20 economically developed states, by about
35 per cent, and the top nominal marginal rate of the inheritance tax
by about 45 per cent (Scheve and Stasavage 2016: 10). As for the global
average statutory corporate tax rate, between 1985 and 2018, it has fallen
by about half, from 49 per cent to 24 per cent (Tørsløv et al. 2018: 1).
The idea that the degree of tax burden affecting the wealthy is the
decisive, if not the exclusive, cause of the intensity of their tax evasion
and avoidance and of the formation and development of tax havens does
not square with the facts. This does not mean that the tax burden has
no influence, far from it. However, it is clear that other elements play an
equally or probably even more important role. Let us now consider these
elements briefly.
Factors Behind the Formation

and Development of Tax Havens
Several studies have highlighted certain factors that contributed to the
emergence and spread of tax havens, such as the multiplication of
sovereign states in the nineteenth and twentieth centuries and, conse-
quently, inconsistent and even contradictory national conceptions of
taxation; the increasing internationalization of the economy and in partic-
ular of capital flows during the same period; the strongly federalist
structure of important states; or the contradiction between the rapid
modernization of certain social formations, on the one hand, and their
attachment to the past, on the other (Picciotto 1992; Hampton 1996;
Palan 2003; Palan et al. 2010). Without denying the influence of these
aspects, it seems to me that they do not go to the heart of the problem.
I would therefore like to draw attention to four factors that these studies
have only touched on at the margin and that seems to me to play a role
14 S. GUEX
that is all the more important because they combine and reinforce each
other.
It is well established historically that the fundamental tendency of any
ruling class since antiquity is to pay as little tax as possible, except when
its very dominance is challenged by an external threat such as war, and/or
an internal threat such as the struggles of the dominated classes (see,
for example, Bihr 2019). However, this tendency of the ruling class is
reinforced in the capitalist system by the system’s very foundations. In
this respect, two factors are at work. On the one hand, since this system
is based on the generalized competition of capitalists with each other, each
individual capitalist can only survive in the long run on the condition of
making maximum profits, and therefore paying the least amount of taxes
possible (Krätke 1984: 156, 168–169, 186). “If industrialists in country
A can sell their products cheaper in country B by escaping taxation, the
firms in the latter country risk being eliminated”, a renowned tax historian
has pointed out (Ardant 1972: 683). The founder of one of the world’s
largest trading companies said, in 1998, that a company “cannot grow
and compete internationally if it does not use tax havens”.5
On the other hand, and more generally, the capitalist system is founded
on the inalienable right to private property, a right that at the same time
reflects and consecrates both the sacralization and the fetishization of
private property and its accumulation by the bourgeoisie. As a result, the
bourgeoisie tends to consider any tax levy that impedes the growth of
private property as a violation of this fundamental right and therefore as
an evil in itself. Thus, in his landmark book published in 1817, David
Ricardo posed as a principle that “there are no taxes which have not
a tendency to lessen the power to accumulate” (Ricardo 1821 [1817]:
164). The same view was held by his contemporary, Jean-Baptiste Say,
who wrote in 1803: “Public contributions, even when they are agreed
to by the nation, are a violation of property…” (Say 1972 [1803]: 134).
A century later, in 1906, discussing the taxation of business, a report
prepared by the highest authorities of the State of California in close
contact with the business community of that state came to the following
conclusion: “A general income tax is un-American. Our people have so
much respect for labour that what is won by honest toil is regarded
5 Claude Dauphin, founder of the company Trafigua, interviewed in Les Echos, 12

November 1998.
as sacred and not to be reduced by direct taxation” (Report of the

Commission 1906: 14).
This element, added to the previous one, implies that within the
possessing classes, the legitimacy of taxes affecting them and, therefore,
the extent to which one is willing to submit to them, remain low, except,
once again, in exceptional times (war, important social tensions) (Krätke
1984: 60–61; Picciotto 1992: 86–92). The tendency of the bourgeoisie
to regard these taxes as a spoliation, and thus as illegitimate, is shown
by the remarkable persistence and the no less remarkable echo of the
discourse presenting any tax burden on the possessing classes as too high,
regardless of its actual height, and thus even when it was in reality very
moderate. In 1850, the economist Frédéric Bastiat wrote that any “pro-
gressive tax” constituted “legal spoliation” (Bastiat 1863 [1850]: 355).
Half a century later, speaking of the British bourgeoisie, the economist
and deputy Leo Chiozza Money pointed out that “the present income-tax
to which such terms as ‘oppressive’, ‘iniquitous’, and ‘intolerable’ are so
freely applied, takes but about 3 per cent of the net income” of the part
of the population with very high incomes (House of Commons 1906:
258). At the same time, in France, Paul Leroy-Beaulieu used exactly the
same terms—along with a few others: “colossal”, “extravagant”, “con-
fiscation”, “theft”, “arbitrary”, “despicable”—to describe the inheritance
tax, of which the nominal rate for very large fortunes inherited in the
direct line of descent was then 6.5 per cent, or to qualify the progressive
income tax then in the making, of which the highest nominal marginal
rate will be set at 2 per cent (Leroy-Beaulieu 1911: I–IV).
Let us now turn to a third factor that contributed to the emergence
and spread of tax havens. The bourgeoisie is characterized by what Alexis
Spire has aptly phrased a “relativistic relationship to the rule”. He explains
that “those at the top of the social space share the certainty that regula-
tions are necessary for the proper functioning of society, but that the
elites must be able to free themselves from them”. And the French soci-
ologist specifies that “in the tax field, this translates into the fact that
these taxpayers […] [are] convinced that any rule can be interpreted,
negotiated, or even neutralized…” (Spire 2012: 12; see also Herlin-Giret
2017). One could not be clearer. Several contributions in this book illus-
trate how the tendency of the bourgeoisie to consider itself above the
law prompts it to disregard or only partially comply with tax rules (van
Beurden; Giddey, Wendschlag; Buggeln; Praz; Ecca; Weidenfeld; Hollis;
Touchelay; Rabault-Mazières; Schönhärl, Düll, Ramirez Lugo).
16 S. GUEX
The three factors that have just been mentioned combine to create
within the possessing classes a mentality—perhaps we should even speak,
with the sociologist Pierre Bourdieu, of a habitus, i.e., a system of norms
and behaviour incorporated by the members of these classes (Bourdieu
1994)—that is particularly hostile to the taxes that affect them, and there-
fore makes them particularly willing to escape from them, even when the
level of their tax burden can be considered low. A fortiori, this state-
ment is valid when this level increases. The strength of this mentality or
habitus is illustrated by the fact that within the bourgeoisie, it can be seen
as proof of “stupidity” or “naivety” for someone not to escape from all
or part of their taxes, and can even call into question their reputation,
or even their social status (Piatier 1938: 16; Praz 2016: 155). In this
respect, the expression “impôt des poires [tax on the duped people]”6
used in 1922 by Louis Loucheur, an important businessman and long-
time Minister, to characterize the income tax in France has become
famous. A few years earlier, in 1907, the editor-in-chief of the daily news-
paper L’Echo de Paris encouraged his wealthy compatriots in an editorial
to entrust their financial wealth to a foreign bank in order to “protect
it” from the tax authorities, whom he characterized as “robbers”, and
repeated several times that those who did not do so, the “honest people”,
were just “stupid”.7
Perhaps the most striking illustration of this mentality or habitus comes
from three examples relating to the Swiss bourgeoisie, each having taken
place a century apart. Thus, in 1812, in the canton of Basel-City, when
the highest effective rate of income tax was as low as 2 per cent, an offi-
cial report noted that “the conscientious bourgeois, who pays his taxes
correctly, is laughed at” because, the report explained, most of his peers
pay “a pittance which does not correspond at all to what they should
pay” (Schanz 1890: 9). Almost a century later, a member of one of the
most powerful families in the same canton said: “We, citizens of Basel,
have never paid taxes on our large fortunes correctly, exactly as the law
requires […]. For the wealthy man in particular, who is still active in
the economy, it is simply not possible to declare his wealth to the tax
authorities calculated down to the last penny. For reasons related to his
6 Journal officiel de la République française. Débats parlementaires. Chambre des Députés,

7 November 1922: 2982.
7 L’Echo de Paris, 19 January 1907.
credit, survival forbids him to fully satisfy his tax obligations. Every citizen
of Basel was fully aware of this”.8 Let us point out that at the time
these words were uttered, the highest nominal marginal rate of wealth tax
reached only 3 per millet and that of income tax 13 per cent (the effec-
tive rates were significantly lower) ( De Cérenville 1898: 81–82 and Table
5; Haitz 1950: 92). Coming full circle, in January 2012, the important
Swiss private banker Konrad Hummler publicly asserted that “whoever
pays taxes is stupid”.9
To understand the fourth factor that contributed to the emergence of
an international tax evasion and avoidance market already before the First
World War, as well as to its evolution during the twentieth century, it
is necessary to insist on an aspect that I have mentioned above. It was
the banking circles in Switzerland, Belgium, England, Germany, etc., that
set up a series of instruments—joint accounts, canvassing of clients on
the spot, procedures ensuring secrecy and anonymity, etc.—intended that
they be entrusted with the management of the financial wealth of the
possessing classes wishing to escape from the taxes of their own coun-
tries, starting with France. It is also banking circles, as well as those of the
tourism industry, which, in Switzerland and most probably in Germany,
perhaps also in France as well as in other countries, have worked for an
almost complete tax exemption of foreign rentiers living off their wealth
in order to incite them to stay durably, or even to reside, on their terri-
tories. It is the business leaders in the industrial and banking sectors
who—in Switzerland and most likely also in Belgium and probably in
England as well as in one or two other countries—have pushed author-
ities to adopt tax privileges intended to encourage the establishment on
their territory of domiciliary companies by foreign firms.
In short, the banking and tourism sectors were the driving forces
behind the development of what several authors have called, much later, a
tax evasion and/or avoidance “industry” (Cosson 1971; Swiss Trading SA
2011: 233; Sikka and Willmott 2013; Rostain and Regan 2014; Ogle
2017: 1435; Noël 2018: 107; Ballenegger and Hollis in this volume),
an “industry” that was and still is often involved—but I won’t go into
this dimension, which is largely outside the scope of this paper—in the
laundering of “dirty” money, i.e., of income from illegal activities such as
8 Quoted in Basler Nachrichten, 20 December 1908.

9 Quoted in Neue Zürcher Zeitung am Sonntag, 29 January 2012.
18 S. GUEX
drug trafficking, corruption, prevarication, etc. (Godefroy and Lascoumes

2004). The banking sector played this role because it siphoned off
foreign capital that sought to escape from tax authorities, which enabled
it to develop two market segments: wealth management and interna-
tional financial operations. It should be noted that these activities tend
to generate higher profitability than usual financial transactions, because
the services related to tax evasion or avoidance are at the limit of legality
or beyond it, and therefore can be sold at better prices. As one banking
expert points out, banks that specialize in dealing with tax evaders and
avoiders achieve “considerable margins at comparable low costs”, which
means that they are “highly profitable” (Birchler et al. 2013: 48; for an
example of these margins, see Hearings 1937: 131–132). As for leaders
in the tourism sector, by attracting a large number of wealthy individuals
for long-term or even permanent stays in the country, they were able to
profile themselves in the most profitable segment of the industry, namely
in sedentary luxury tourism. These kinds of tourists brought the advan-
tages of high expenditures, but also of entrusting local bankers with the
management of all or part of their movable assets (Guex 2021: 5–6).
Both the sectors of banking and tourism can therefore be considered
pillars of the development of the tax evasion and avoidance “industry”.
However, this “industry” has included or interested, and still interests,
much wider circles, starting with the numerous lawyers, notaries, finan-
cial companies, insurance companies, accounting firms, trust companies,
tax consultancies, etc., in short, the “merchants of law” (Dezalay 1992;
see also Hampton 1996: 18–33; O’Hara and Ribstein 2009; Surak 2020)
and/or of “tax consultancy” (Spire 2011: 67). They have also contributed
and still contribute powerfully to the development of this “industry”
from which they derive very substantial revenues. In addition to these
circles, which benefit directly from tax evasion and avoidance, there are
many other social groups within the bourgeoisie, the petty bourgeoisie
and even wage earners who benefit indirectly. Let us name some impor-
tant examples. The attraction of foreign capital, which is not subject
to taxation in its country of origin, tends to lower interest rates in the
country of arrival, which in turn tends to increase the competitiveness
of industrial employers. The sedentary luxury tourism and the arrival of
foreign companies stimulate the luxury industry and trade (watchmaking,
jewellery, art market, etc.), push up the land rent, spur the construction
sector, encourage the development of the educational (private schools
and universities) and medical (private medical institutions) “industry” and
benefit important groups of employees in all the sectors that have been
mentioned so far, from bank executives to the domestic staff of luxury
homes (Rawlings 2004: 333; Guex 2021).
Last but not least, this predation of wealth and profits from other coun-
tries, and thus of the corresponding tax revenues, has tended and still
tends to increase the tax revenues of predatory jurisdictions and thus to
improve their competitiveness, both in terms of expenditures (they allow
for the establishment of quality conditions for production: infrastruc-
ture, education, etc.) and in terms of taxation (they allow for a relatively
moderate tax burden on resident individuals and companies). In the glob-
alized capitalist system, in which companies and their respective states
are in fierce competition, such advantages have been and continue to be
considerable assets. As early as 1897, Paul Leroy-Beaulieu, in an edito-
rial about escaping taxation through the transfer of financial wealth to a
foreign country, emphasized the advantage that this had for the recipient
country: “Wherever the hidden sources of this wealth and income may
be, a part of it falls indirectly into its hands”.10
The Predatory Role of Tax Havens

The importance of the aspects discussed above cannot be overestimated.
Indeed, they call into question the current explanatory scheme of the
emergence and development of tax havens. Let us recall that in the
traditional view tax havens were born and developed because taxpayers
were pushed by the increasingly excessive taxation of their own state to
escape all or part of their income and/or wealth from the tax authori-
ties by transferring it to foreign jurisdictions. According to this vulgate,
strongly influenced by the vision that tax havens have given and still give
of themselves, the only active agents of this type of tax non-compliance
are therefore the tax evaders or avoiders themselves. To use an expression
borrowed from the historian Mark Spoerer, tax havens are considered
essentially as “passive” agents, as repositories of the capital escaped from
tax authorities, their “active” participation being limited to offering
these funds—once they have been received—possibilities of valorization
in the national economy or on the international market (Spoerer 2004:
10 L’Economiste français, 30 October 1897: 562.

20 S. GUEX
180). The expressions that have become commonplace—tax “havens”,

“refuges” or “oases”—are evidence of the notion that tax havens are the
passive, almost involuntary, product of decisions made and implemented
by tax evaders or avoiders alone.
What we have seen shows that this conception, once again, only
partially squares with reality. In fact, a fraction of business circles in several
economically developed countries has begun to specialize in setting up
instruments designed not only to offer the possibility for possessing classes
of other countries to evade or avoid the taxes levied in their respective
states but also to induce them to do so. Such specialization has been
sufficiently successful—in terms of direct and indirect profits—to interest
ever wider sectors of the bourgeoisie and beyond, so that it has become a
business or an “industry” in its own right, protected and promoted by the
State itself, almost in the same way as relating to the other components
of the national economy.
It is therefore impossible to fully understand the formation of tax
havens, let alone their development, without considering the fact that they
are also the products of a deliberate and active policy of important, even
central, sectors within the ruling class of certain states (see Ballenegger;
Watteyne; van Beurden; Lejour; Fyfe in this volume). These sectors not
only respond to demand with supply but tend to go further. As with any
market, they also try to create or stimulate demand. In other words, they
use taxation as a lever for their own accumulation, siphoning off part of
the wealth produced or held in other states and depriving them of the
equivalent tax revenues. In this sense, they can be characterized as para-
sites or predators. A member of French Parliament noted, in 1911, that
“the Swiss banks are the leeches of French capital”, and deplored the fact
that “our French capitalists […], moved by certain tax fears, deposit their
money in Swiss banks”.11
Why did the injured states not prevent the establishment and devel-
opment of these predatory activities? The question is important because
it concerns not only the emergence of tax havens, but their noteworthy
longevity and their no less outstanding multiplication from the 1970s
onwards. Let us specify that again, it is only possible to sketch out some
answers.
11 Maurice Ajam, article entitled “Le nerf [The nerve]” published in the daily newspaper
La France militaire, 27 July 1911.
Many researchers have rightly come to the following conclusion: tax

havens could not have survived, let alone developed, if a certain number
of states, especially the most powerful ones, had waged a determined and
persistent struggle against them. And they agree that the attitude of the
latter towards tax havens has been characterized throughout the twentieth
century by their “tolerance” (Hampton 1996: 94), “ambivalence” (Eden
and Kudrle 2005: 122), “complacency” (Farquet 2016: 470) or “lack of
political will” (Palan et al. 2010: 219; Hollis and McKenna 2020: 177).
However, it seems to me that the causes of this tolerance have not yet
been discussed and identified with sufficient clarity. In this regard, the
literature has so far identified two main factors that, by simplifying, can be
summarized as follows (Hampton 1996: 68–119; Palan et al.: 153–225;
Farquet 2016: 467–471):
1. In the manner of what had happened, in Switzerland, in particular,
before the First World War, and no doubt stimulated by the success of the
Swiss tax haven, important sectors of the capitalist class in many economi-
cally developed countries, including the great powers, in the course of the
twentieth century also sought to position themselves in the international
tax evasion and avoidance market, in other words, to transform their own
states into tax havens (Palan et al. 2010: 111–149).
2. The existence of tax havens has undeniably allowed many capital-
ists and wealthy individuals as well as many companies to escape from
the tax authorities of their own state and thus to increase their accu-
mulation of wealth and, as far as companies are concerned, their rate
of profit and thus their competitiveness. In short, as two historians
conclude in a recent study: “Administrators in Britain, France, Germany,
and the United States all selectively tolerated offshore activity insofar
as they believed it contributed to national competitiveness” (Hollis and
McKenna 2020: 177). Additionally, any serious fight against the interna-
tional tax evasion and avoidance market required the adoption of rigorous
measures—for example, an extensive financial and even economic boycott
of tax havens—that could significantly impede the functioning of the capi-
talist system as a whole. In the same vein, any struggle by one or a few
states against tax havens implied a high risk not only of failure, due to a
lack of power, but also of penalizing and thus endangering local compa-
nies compared to their competitors established in countries that did not
wage such a struggle. To combat tax havens, it would therefore be neces-
sary to form a broad coalition of states, including at least a few of the most
Another random document with
no related content on Scribd:
usaba de su cuerpo como pública
ramera, y otro autor que dixo que
Pan, dios de los pastores, fué hijo
suyo y de Mercurio, y que por
saber esto Ulises hizo divorcio
con ella y se fué á vivir á la ínsola
Cortina; y otros muchos que
hablando de su vida trataron della
como de mujer que había vivido
deshonestamente y que no
solamente tuvo por hijo al dios
Pan, sino á otros muchos de
diferentes padres, hechos en
adulterio; y si Virginea fué muerta
por no consentir en la
desenfrenada voluntad de aquel
varón de los diez que entonces
gobernaban á Roma, que por tan
exquisitas y desvergonzadas
formas y maneras procuraba
gozar el amor ilícito y deshonesto
que con ella tenía, fué porque su
padre hizo sacrificio de la hija por
no recebir la afrenta que viviendo
le estaba aparejada, que si á la
voluntad de Virginea lo dexaran,
por ventura excusara la muerte
con dexarse corromper su
honestidad antes que recebir las
puñaladas que le fueron dadas
por su padre; así que no estés,
Torcato, tan confiado de la tu
Belisia que no puedas presumir
que por haber puesto sus amores
y voluntad en otra persona haya
dexado los que contigo tenía,
porque esto es lo que yo por más
cierto tengo.
Torcato.—Y yo por más incierto,
porque no me podrás inducir con
tus enxemplos que pueda creerlo;
porque ya que fuese verdad lo
que has dicho, ¿cuántas mujeres
ha habido y hay en el mundo tan
castas que ninguna mancilla se
puede poner en su bondad? Y si
no mira lo que hizo la reina Dido
por no querer consentir en los
amores del rey Yarvas, ni que
después de la muerte de su
marido Sicheo hubiese quien
pudiesse triunfar de su
honestidad, y así escogió por
mejor dexar hacer ceniza su
cuerpo en el ardiente fuego que
no dar lugar á que otro ninguno
pudiese gozar de lo que él había
gozado; aunque el poeta Virgilio,
no sé por qué causa ó razón
inducido, quiso poner en su
bondad y buena fama la mancilla
que puso, diciendo que había
tenido amores con Eneas, siendo
falsedad averiguada, porque Dido
fué mucho tiempo antes que
Eneas, saliendo de Troya,
anduviesse peregrinando por el
mundo; y sin tratar de las mujeres
antiguas, ¿cuántas en nuestros
tiempos se sojuzgan al
incomparable trabajo de las
religiones, haciendo sacrificio de
la vida hasta la muerte, y otras
que han tenido por mejor que sus
cuerpos fueran despedazados
que no consentir en que por su
voluntad la castidad fuesse en
ellas violada? Sola Susana
bastaba para quitar las lenguas
de los maldicientes, viendo con
cuánta firmeza procuró guardarla
de aquellos viejos que procuraban
aprovecharse della, teniendo por
mejor ser por su falso testimonio
condenada á la muerte que
consentir en sus torpes desseos.
Y sin ésta, te podría decir otras
muchas que bastan en nuestros
tiempos á defenderse de la
importunidad de los hombres, sin
dexarse jamás vencer para que
su castidad corra peligro, ni ellas
se puedan dexar de llamar
mujeres castas; y para que mejor
entiendas la ventaja que en esto
hacen las mujeres á los hombres,
mira lo que se usa en muchas
partes y entre muchas naciones
de gentes idólatras, que en
muriendo los maridos se matan y
se entierran, ó se queman con
ellos, por su propia voluntad, y
mostrando muy gran
contentamiento en huir de los
peligros en que quedaría su
honestidad siendo viudas, y no
verás hombre ninguno que haga
lo mesmo aunque se le mueran
cien mujeres; y ten por cierto que
muchas habría en la christiandad
que seguirían esta mesma orden
si el temor de la perdición de sus
ánimas no se lo vedase.
Filonio.—En cargo te son las
mujeres, que assí quieres
defender contra la común opinión
de todo el mundo ser hechas de
otra differente condición y
costumbres de las que tienen y en
ellas se conocen; continuamente
todos cuantos han escrito, cuando
vienen á hablar en ellas, no hallan
palabras que basten á contar sus
vicios y torpezas; los libros están
llenos dello, y no solamente los
proffanos, pero también los de la
Sagrada Escriptura, y si no
pregúntalo á Salomón y verás con
cuán encarescidas palabras las
pone muchas veces del lodo,
tratándolas como ellas lo
merecen. Y en un libro que yo oí
una vez leer decía que la mujer
nunca era buena sino una vez en
la vida, y que ésta era la hora que
se moría, y que era mejor cuando
más presto se muriese; y con
estas palabras consolaba un
amigo á otro porque su mujer se
le había muerto.
Torcato.—Bastaría que alguna
mujer te hubiesse á ti tratado
como á mí me ha hecho Belisia
para que tanto mal me dixeses
della y de todas las otras mujeres;
pero no quiera Dios que yo con
pasión me ciegue para decirlo, ni
para consentir que tú pienses que
tienes razón en lo que dices. Y lo
primero que quiero preguntarte es
quiénes son esos que escribieron
los libros que has dicho.
Filonio.—¿Quiénes han de ser
sino hombres muy sabios y
avisados que las tienen bien
conocidas?
Torcato.—Bien se parece que
son hombres, que si fueran
mujeres harto más tuvieran que
poder decir y escribir y con mayor
verdad de los hombres que no los
hombres dellas, porque
verdaderamente muy mayores y
más torpes y más comunes son
los vicios en los hombres que en
las mujeres, y nosotros, que las
notamos y acusamos de parleras
y desenfrenadas en sus lenguas,
somos los que las infamamos
diciendo tantos males dellas, que
debríamos de tener vergüenza de
que nuestras palabras saliessen
por nuestras bocas tan
perjudiciales contra personas de
quien tantos bienes recebimos; y
aunque haya algunas malas entre
ellas, yo fiador que no sean tantas
como los hombres, y nosotros
mesmos somos la principal causa
de sus males, importunándolas y
fatigándolas con promesas, con
engaños, con lisonjas y con
persuasiones que bastarían á
mover las piedras, cuanto más á
mujeres, para que algunas veces
vengan á dar en algunos yerros; y
ellas jamás nos importunan ni
fatigan requiriéndonos, y
molestándonos con
desvergüenza, antes tienen por
mejor callando passar sus
trabajos, que no dar á entender lo
que por ventura con su flaqueza
les piden sus apetitos. Y los que
escribieron contra ellas no fué
contra las buenas, sino contra las
malas, y lo que dixeron de las
unas, siendo pocas, no se ha de
entender de las otras, que son
muchas; así que sería mejor que
todos nosotros nos empleásemos
en decir bien de quien tantos
bienes habemos recebido y
recebimos cada día, y no mal de
quien ninguno nos merece; y si
alguna nos diere causa, con
algunos desatinos, á que
podamos decir mal della, sea
particularmente para reñirla y
castigarla con palabras y obras,
siendo necessario, y no queramos
que paguen las justas por las
peccadoras y las que no tienen
culpa por las que merecen el
castigo; que lo que fuera desto se
hiciere ó dixere, será mal dicho y
mal hecho, y los vituperios y
infamias y deshonras quedarán
en aquellos que las dixeren,
queriendo por una mujer mala
hacer á todo el género de las
mujeres malas, siendo por la
mayor parte buenas y tan buenas
que plugiesse á Dios que no
fuéssemos nosotros peores que
ellas; y concluyendo digo que yo
no tengo la sospecha que dices
de que Belisia por haber tomado
amores con otro haya dexado los
míos, y primero lo habré visto por
los ojos que lo confirme en el
pensamiento.
Filonio.—Paréceme, Torcato,
que hablar alguna cosa en
perjuicio de Belisia es tocarte á ti
en el alma, y pues que con tanta
afición y tan apassionadamente
defiendes lo que le toca, yo no te
veo otro remedio para salir deste
piélago en que estás metido sino
esperar á que el tiempo vaya
consumiendo el agua poco á poco
hasta que te halles en seco, y
entonces juzgarás las cosas muy
diferentemente de lo que agora lo
haces.
Grisaldo.—Con estas pláticas se
nos ha pasado el día, y pues que
ya, Torcato, has descansado con
decirnos tu fatiga y nosotros
quedamos obligados á procurar tu
remedio y consuelo en todo lo
que pudiéremos hacerlo, aunque
sea contra tu parecer y voluntad,
procura de dexar la compañía de
la soledad con que andas, porque
con la conversación no tiene tanto
lugar la tristeza que sin sentirlo te
consumirá la vida, y agora todos
nos vamos al lugar, donde los
regocijos de las bodas de
Silveyda no serán aún acabados,
y podremos llegar á tiempo que
gocemos alguna parte dellos.
Torcato.—Haced lo que os
pareciere, que determinado estoy
á forzarme y seguir vuestro
consejo.
Filonio.—Pues ¡alto! ¡sus!
caminemos, y para que menos
sintamos el camino, vamos
cantando alguna cosa con que
tomemos placer, que, según veo,
bien será menester para que
Torcato deseche parte de la
tristeza con que anda.
Torcato.—Yo quiero comenzar
unos versos que hice en este
desierto, al propósito de lo que mi
corazón siente; vosotros me
ayudad, para que mejor pueda
cantarlos.
Grisaldo.—Comienza á decirlos,
que así lo haremos.
TODOS TRES PASTORES

Montes, sierras y collados,
que entendido
habéis mi pena rabiosa y mis
dolores,
escuchando mis fatigas y
querellas
que al alto cielo han subido,
rompiendo con mis clamores
las estrellas,
Doleos de mis trabajos y
fatiga;
llorad conmigo mis ansias y
mis males;
moveos á compasión de mi
tormento,
pues la dulce mi enemiga
quiere sean mortales
los que siento.
Los ríos desta montaña, con
las fuentes,
testigos de mis fatigas y
cuidados,
cansados ya de me ver con
mis enojos,
detengan hoy sus corrientes,
dando lágrimas parados
á mis ojos.
Tú, Eco, que estás contino
resonando,
de mis llantos grande amiga y
compañera,
llevando mis tristes voces por
los vientos,
no dexes de ir publicando
cómo me acusan, que muera
mis tormentos.
Y tú, mi ganado triste y
afligido,
con pastor tan sin ventura y
desdichado,
que alredor deste acebo
andas paciendo,
aquí te estarás tendido
tomando en ti mi cuidado,
y padesciendo.
Soledad muy agradable, y
compañía
á mis tristes pensamientos y
memoria,
con la cual siempre descansa
mi tristeza,
no dexes de ser mi guía,
porque sienta en ti su gloria
mi firmeza.
Belisia, si mis clamores han
herido
tus oídos, yo te ruego que
escucharlos
quieras con lástima alguna y
compasión
de verme tan afligido,
y no quieras ataparlos
sin razón.
Porque si no remediares mi
dolor,
á mí me basta que sepas que
padezco,
con entera libertad, y así lo
quiero,
con muy verdadero amor,
pues á la muerte me ofrezco
y por ti muero.
Fin.
Á LOOR Y HONRA DE SEÑOR JESUCHRISTO Y
DE SU BENDITA MADRE SANTA MARÍA,
NUESTRO AMPARO Y GUÍA, FUERON

IMPRESSOS LOS
SIETE COLLOQUIOS EN LA CIUDAD DE
MONDOÑEDO
EN CASA DE AGUSTÍN DE PAZ, IMPRESSOR
ACABÓSE Á XXV DÍAS DEL MES DE OCTUBRE

DEL AÑO
DE MDLIII
NOTAS:
[1274] Remedio dice la edición de Mondoñedo, añadiendo una
sílaba al verso.
Tetuán de Chamartín.—Imp. de Bailly-Baillière é

hijos.
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Tax Evasion and Tax Havens Since The Nineteenth Century Sebastien Guex Full Chapter

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Tax Evasion and Tax Havens since the

Nineteenth Century Sébastien Guex

Tax Evasion and Tax

ISBN 978-3-031-18118-4 ISBN 978-3-031-18119-1 (eBook)

implemented by states to attract them to their territory, for example,

Lausanne, Switzerland Sébastien Guex

1 Introduction. “Low-Tax Predators” Rather Than

Part I Emergence and Expansion of Tax Havens

6 Swedish Emigration to Switzerland

Part II Tax Evasion: Extent, Causes, and Conflicts

Part III Fighting Tax Evasion and Tax Havens?

15 Tax Evasion as Seen by French Tax Administrations

About the Editors

Sébastien Guex is Full Professor of History at the University of

by the Swiss National Science Foundation entitled ‘The Antechambers of

Hadrien Buclin is a part-time Lecturer at the University of Fribourg,

Vivien Ballenegger is a Ph.D. candidate at the University of Lausanne.

global history of capitalism. He is the author of ‘Union Cold Storage

Korinna Schönhärl is Professor of Modern History at the University of

is the author of Aux sources de l’impôt en Belgique. Une histoire de conflits

Fig. 2.1 The emergence of tax havens in the twentieth century

Fig. 6.2 Distribution of Swedes in Swiss cantons by tax index,

Fig. 10.1 An estimation of tax evasion on wealth based

Fig. 12.6 Municipal Spending (Notes This figure shows

Map 6.1 Swedes in Switzerland: communal distribution (1980)

Table 6.1 Swedish emigration and immigration

Table 11.2 Summary diagram of the application of the reduction

Introduction. “Low-Tax Predators” Rather

The numbers are astronomical. According to a study presented in

I am very grateful to Janick Marina Schaufelbuehl for her valuable assistance in

© The Author(s), under exclusive license to Springer Nature 1

A History Still in Its Infancy

2 Neue Zürcher Zeitung, 6 April 2013.

A New Periodization and Its Consequences

1. From the second half of the nineteenth century, at the insti-

totally exempted a certain category of residents from taxation: the

3 See Neue Zürcher Zeitung, 17 December 1869, Gazette de Lausanne, 27 December

Banks in other countries—not only the United Kingdom, in

3. In the decades immediately preceding the First World War, compe-

the issuance of loans, sales and purchases on the stock exchange,

Despite many remaining uncertainties, it is therefore possible to affirm

4 See Annales parlementaires de Belgique—Chambre des Représentants, 7, 12, 13 and

to these classes’ ideology, which is mostly economically liberal and util-

accomplished through foreign jurisdictions and was thus accompanied,

Factors Behind the Formation

5 Claude Dauphin, founder of the company Trafigua, interviewed in Les Echos, 12

as sacred and not to be reduced by direct taxation” (Report of the

6 Journal officiel de la République française. Débats parlementaires. Chambre des Députés,

8 Quoted in Basler Nachrichten, 20 December 1908.

drug trafficking, corruption, prevarication, etc. (Godefroy and Lascoumes

The Predatory Role of Tax Havens

10 L’Economiste français, 30 October 1897: 562.

180). The expressions that have become commonplace—tax “havens”,

Many researchers have rightly come to the following conclusion: tax

TODOS TRES PASTORES

NUESTRO AMPARO Y GUÍA, FUERON

EN CASA DE AGUSTÍN DE PAZ, IMPRESSOR

ACABÓSE Á XXV DÍAS DEL MES DE OCTUBRE

Tetuán de Chamartín.—Imp. de Bailly-Baillière é

Updated editions will replace the previous one—the old editions

Creating the works from print editions not protected by U.S.

START: FULL LICENSE

To protect the Project Gutenberg™ mission of promoting the