8. We found that to date Mapeley has paid no tax in relation to rental income on offshore properties, as it has been able to use losses to offset any chargeable income. This is in line with its offshore model. It is difficult to compare what tax would be due were Mapeley onshore, as it is likely that it would have increased its price, thereby changing the profile of rental income and associated tax due. Mapeley's onshore model predicts that in an onshore scenario with HMRC paying a higher price, it would have paid around £13 million in tax by March 2009.
9. Mapeley expected that the majority of the tax advantages would arise at the end of the contract. The estimated tax payable over the 20 years of the contract if Mapeley was onshore was £184 million in cash terms, compared with £14 million in the financial model with Mapeley offshore. This gives Mapeley savings of £170 million in cash terms, £106 million of which arise in the final year of the contract on expected gains from the sale of properties. Whether Mapeley ultimately obtains higher or lower tax savings than anticipated remains uncertain. It will depend on various factors including the timing, scale and gains on disposals of property, operating profits and losses, and tax rates in force.