Building a tax fairyland in Luxembourg in five not-so-easy steps

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The Walt Disney Co., in 2009, moved a bit of its magic kingdom into the Grand Duchy of Luxembourg.

In a 34-step restructuring of its foreign operations, the parent company of Mickey Mouse and Cinderella established three companies in the tiny country nestled between Belgium, Germany and the Netherlands, and proceeded to move more than 20 of its subsidiaries under their corporate umbrella.

Here, in five steps, is how the company gathered ownership of its empire, from Australia to Denmark to the Cayman Islands, into Luxembourg. The documents are in the original French and were translated for the International Consortium of Investigative Journalists (ICIJ).

1) Disney’s Netherlands subsidiary transfers ownership of five companies worth $522 million into a Luxembourg company referred to in the documents as WedcoLux 1.

2) A Disney U.S. subsidiary called Wedco International Holdings Inc. transfers ownership of 16 companies such as The Walt Disney Company Germany and Buena Vista Television Australia, worth €2.1 million, to a second Luxembourg company referred to as WedcoLux 2.

3) WedcoLux 1 and WedcoLux 2 transfer their shares into the third Luxembourg company, which is simply referred to as Wedco S.C.A.

4) WedcoLux S.C.A. transfers ownership of many of those companies to a U.K. company called Walt Disney International Ltd., which is already a subsidiary of WedcoLux S.C.A.

5) WedcoLux S.C.A. moves ownership of WDI Ltd., and by extension more than a dozen Disney subsidiaries in Europe and Australia, into a Cayman Islands-registered company called Hammersmith Ltd.

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