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Big Pharma corporations like Pfizer, Novartis, Glaxosmithkline, - as well as over 60% of Fortune 500 multinationals, all maintain entities in Delaware, taking full advantage of ring-fenced legal and financial opacity tools. In addition to banking secrecy and zero disclosure of beneficial owners, Delaware allows for parent companies to establish holding companies within two days, producing nothing, conducting no economic activity in the state, and generally hosting just one shareholder (the parent company). Such entities, allowing the parent company to pay the newly created entity a 'fee' for use of IP, serves as a passive conduit converting taxable income to passive non-taxable profit. The entity's sole purpose is to own and 'manage' laundered income generated from IP.

Intentionally weak and easily circumvented global rules regulating trade facilitates considerable leeway to exploit - and misprice, the value of intangible assets. A Pfizer patent, for instance, may be worth $100 million or a $10: by and large, the company internally determines the value of IP, imputing a 'market price'.

Intra-company mispricing not only distorts and manipulates the proposed neoliberal concept of the market (as most efficient allocator of price and resources), but simultaneously drains developing countries of sustainable tax revenues

This is the case precisely because the kind of politics that has now taken a firm grip on South Africa and most other societies around our globe is embedded in a system of neoliberal capitalist social and productive relations whose prime vehicle has been business. The very essence of this system is to construct and run societies based on individualised and privatised material benefit, the ‘ethics’ of accumulative greed and self-aggrandisement as well as institutionalised injustice and inequality. 


Thus, when we take a critical look at the contemporary polipreneurship that has been borne out of this systemic frame, we cannot just focus on the politicians, political parties and private business sectors; we have to also look at ourselves.

In this reality the lines between business and politics have effectively disappeared. There is no foundational difference between: Premier Foods colluding to fix the bread price (and then using their corporate and monetary power to make sure that they mostly get away with it); and, the ANC and its leaders colluding to ensure their self-constructed ‘investment’ vehicle - Chancellor House - directly benefits from government mining policies (and then using their political and institutional power to arrogantly dismiss any wrongdoing and also get away with it).


development finance siphoned from Africa, whether through the extractive industries, or land grabs, are unlikely to be revealed as the IMF scrapped mandatory information exchange. Global watchdogs, such as the Financial Action Task Force (FATF) remained beholden to high-income nations as a ‘subsidiary’ unit in the Organisation of Economic Co-operation and Development (OECD). Meanwhile, the International Accounting Standard Board (IASB), founded and finance by the ‘big four’ accounting firms – maintaining units in secrecy jurisdictions such as the Cayman Islands – prefers multinationals to self-regulate trade via arms length transfer. What this effectively does is enable multinationals, conducting 60 per cent of global trade within rather than between corporations, to determine the future of entire continents such as Africa, where primary commodities – extracted by corporations, account for 80 per cent of exports.

Studies by the International Institute for Environment and Development (IIED) revealed, ‘Many countries do not have sufficient mechanisms to protect local rights and take account of local interests, livelihoods, and welfare. Moreover, local communities are rarely adequately informed about the land concessions that are made to private companies. Insecure local land rights, inaccessible registration procedures, vaguely defined productive use requirements, legislative gaps, and other factors all too often undermine the position of local people vis-à-vis international actors.’[1]

the presence of tax havens, whether specialising in corporate or maritime services, consistently undermines national and international rule-of-law. This was the case with the capitalist apartheid regime in South Africa, who circumvented oil sanctions through the 'socialist' government of Seychelles. The Iranian revolution evidenced the fall of the US-backed Shah, depriving the apartheid regime of secure oil supplies.

By pyramiding holding companies in jurisdictions characterised by secrecy, the corporate beneficiaries of the apartheid regime were able to access resources and labour on the cheap, while easily navigating global sanctions.

Not much has changed when it comes to the use of secrecy jurisdictions as a means of looting African minerals. Until recently, Sierra Leone’s diamond industry was dominated by two firms: SLDC and Koidu Holdings. The latter was wholly owned by two entities based in tax havens, both of which are directly connected to the UK: Guernsey and the British Virgin Islands (BVI) through BSG Resources, recently implicated as a potential funder for Zimbabwe's Marange fields (via Canadile).