Avis Capital Limited is one of the largest companies in the UK. It says it was spun out from Avis (the car hire company), is FCA-regulated and has £58bn of net assets. It promises investors a 31% return. But all of this is a lie.
Avis Capital’s accounts are a work of fiction. It’s completely unregulated, and the financial products it sells appear to be fraudulent. It has no connection to the real Avis group. All of this has been facilitated by Companies House accepting filings and accounts which are false on their face, and by accounting firms who failed to notice obvious signs of fraud.
Companies House’s failure to identify and act on this is a scandal. It could be taking simple steps to stop UK company law being used and abused by criminals. But it isn’t.
We are aware of even worse cases, and will be reporting on them shortly.
Avis Capital – the 13th wealthiest company in the UK
Here’s Avis‘ Capital‘s 2021 accounts – it made a £48bn profit on an initial £10bn, resulting in £58bn of net assets. That would make it the thirteenth biggest company on the FTSE.
![Balance sheet for Avis Capital Limited as at 30 November 2021: AVIS CAPITAL LIMITED
Registered number: 10465466
Balance Sheet
as at 30 November 2021
Notes | 2021 £ | [illegible]
Fixed assets
Tangible assets | 3 | 128,166,038 | 125,1[illegible]
Investments | 4 | 690,874,193 | 635,7[illegible]
819,040,231 | 760,8[illegible]
Current assets
Debtors | 5 | 48,133,044,418 | 48,183,888,539
Investments held as current assets | 6 | 855,349,882 | 855,349,882
Cash at bank and in hand | 24,404,296,829 | 24,427,460,722
73,392,691,129 | 73,466,699,143
Creditors: amounts falling due within one year | 7 | (16,056,475,889) | (16,048,987,553)
Net current assets | 57,336,215,240 | 57,417,7[illegible]
Total assets less current liabilities | 58,155,255,471 | 58,178,5[illegible]
Creditors: amounts falling due after more than one year | 8 | - | (324,8[illegible])
Net assets | 58,155,255,471 | 57,853,7[illegible]
Capital and reserves
Share premium | 10,000,000,000 | 10,000,0[illegible]
Profit and loss account | 48,155,255,471 | 47,853,7[illegible]
Shareholders' funds | 58,155,255,471 | 57,853,7[illegible]](https://taxpolicy.org.uk/wp-content/uploads/2025/01/image-18.png)
The 2020 column to the right is cut off, but the numbers are almost the same.
The company then repeated this magic trick in 2022 and 2023: the accounts are identical, to the pound, for each year:
Trade debtors and creditors, fair value of investments… it’s all the same, every year.
All while showing no sign of paying any tax on its £48bn profit, and all while claiming the company is dormant.
Avis Capital is claiming that a multimillion pound business was in exactly the same financial position for three successive years (and almost exactly the same for the previous year). That is not possible – all that cash and other investments will yield a return, that will be taxable, the company will have expenses… all mean that the numbers will inevitably change from one year to another. One expert told us that, for any company with real activities, it was “essentially impossible” for every line on a balance sheet to be unchanged from one year to the next. That’s true for a coffee shop: it’s certainly true for a £58bn financial giant.
Avis Capital Limited applied Section 1A of FRS 102, simplified accounting standards for small companies. These are inapplicable to a large company like Avis Capital. More significantly, accounts for large companies are required to be audited. Avis Capital Limited filed unaudited accounts.1
The accounting experts we spoke to were certain these accounts are fraudulent. 2
Avis Capital – in reality
We have extensive contacts in banking and finance, in the City and across the world. Nobody has heard of Avis Capital.
The company’s website says it has 150,000 employees. This is its registered office: an estate agent in Brixton:
Avis Capital has almost no internet presence aside from its own website,3 which is full of claims like this:
![Slide from a promotional presentation claiming to 3D print industrial green cities in Spain and Colombia: ... we 3D print the industrial green cities worldwide
SPAIN CARTAGENA
AGENA
We are developing the first European industrial green city center on 25 million m2 of land. 20 million tones of waste milling into nanopowder for the 3D printing manufacturing in composite, construction of buildings and consumer products.
COLOMBIA
Turks and Caicos Islands
ands
Jamaica
Puerto Rico
Aruba
Curaçao
[Text overlay on map, left side:]
ered 85km x 48km
truction of a green
dustrial smarth city
10 million peoples
[Text overlay on map, right side:]
The AVIS Team will o[illegible]
entering into the cons[illegible]
with the authorization [illegible]
Central Bank of repa[illegible]
€500bln off-balance [illegible]
We have developed the first South American industrial green city center on 50 million m2 of land since 2016. 30 million MT of waste we converted into nanopowder and in composite construction of building and consumer products.](https://taxpolicy.org.uk/wp-content/uploads/2025/01/Screenshot-2025-01-24-at-22.32.15-2000x1569.png)
The website says Avis Capital was spun out of “the AVIS Car corporation” in 2005. There is no “AVIS Car corporation”; the well-known car-hire business is Avis Budget Group, and it has no connection to Avis Capital.4
There’s also a LinkedIn page boasting that it has “twelve digits of construction cash”…
The company has a YouTube channel, with 105 subscribers. The most recent video contains vague claims about a “quantum banking system” delivered by an AI generated voiceover…
Older videos promote financial services through “Avis Bank”:
And, from 2014, there’s a video promoting the “Avis Humanitarian Foundation”, complete with a music video covering Michael Jackson’s “We Are The World”.
Aside from Companies House filings and websites/YouTube, the only evidence we can find of Avis Capital’s existence is that on two occasions it was taken to a county court for not paying a debt, a judgment was issued against it, and it didn’t pay:
The Avis Group
There are a series of related Avis companies with similarly suspect accounts:
- Avis Global Green Energy Fund has £19bn of assets and £510m of net assets on its 2023 balance sheet. Its 2022 and 2021 balance sheets are identical.
- Avis Global Energy Ltd holds Avis Capital Limited and so should have at least £85bn of net assets; but its accounts instead show that its investors put in £5bn, and the company is now worth slightly less than that. Its balance sheets are duplicated from one year to another.
- Avis Congress Hotels plc is a dormant company with £1bn in cash, and identical balance sheets from 2018 to 2023.
- Avis Fintech PLC supposedly has £100m of cash, and has done every year since 2019, with no change in its balance sheet.
- Avis Global Group PLC supposedly has £8m cash in the bank, with its balance sheets never changing.
- Avis Magnetic Technologies PLC supposedly has £10m cash.
- Avis Logistic Ltd has £1m in unspecified current assets.
- Avis Atom Threads PLC has £2bn in “called up share capital not paid” – in other words, the shareholders acquired £2bn of shares but didn’t pay immediately. That is less obviously fraudulent than claiming to have £2bn in cash, but is still not very plausible (normal people don’t agree to acquire shares which means they owe large sums of money to a company).
- Avis Noage PLC, Avis Vortex Industries PLC, Avis Nuctron PLC – all have £1bn in “called up share capital not paid”.
Since we published this report, Ray Blake has noticed a 2024 incorporation from the same people:
- Join Asset Ltd was supposedly incorporated with £1bn paid up shares. It has a website with the same peculiar art style as Avis Capital, and similar vague business descriptions (“tokenised assets”). The website says their values are “honesty, integrity, and transparency”.
The fraud
Why would someone, or a group of people, create a ring of fake companies?
The most likely scenario is that these companies are part of an attempt to defraud investors.5.
We see two potential frauds here.
The first involves Avis Global Energy Ltd, the holding company of the supposedly extremely valuable Avis Capital. Its 2022 confirmation statement shows 70 shareholders, mostly small investors who’ve acquired shares from 2017 to 2022. If these investors paid money for their shares then that could be the fraud: create a fake company, and convince people to buy shares in it.
The second is more complex, and is revealed by legal documents listed on the Avis Capital website, all of which suggest it is selling sophisticated financial services. The documents are superficially plausible but contain mistakes and oddities. For example, the call option is headed “Institutional Acquicition” and says it is subject to “the laws of the State of United Kingdom”. 6
Most notably, there’s a detailed fund memorandum – the kind of document produced when a private fund is being marketed to investors. Here’s the full document, dated 2022:
The document refers throughout to UK financial services and tax legislation, and may therefore be targeted at UK investors. However it is also possible that the fraud is targeted at foreign investors, with the UK being used to add credibility to the business.
The key claim in the document is a promise of very high returns:
The high “gross equivalent” return is because Avis claim that their fund qualifies for a 30% tax relief “offered generally from governments”. This claim is false. Most governments do not offer relief for funds like this, investing in large, well-established companies.7
So, whilst the claim of a 17.1% return is (at best) highly optimistic, the claim that tax credits boost the gross return to over 30% is false.
We can be reasonably confident that the arrangement is fraudulent from this paragraph alone:
The Financial Services Authority ceased to exist in 2013, and was replaced by the Financial Conduct Authority and the Prudential Regulation Authority. None of the Avis companies are authorised by the FCA or the PRA. There is no such thing as a “registered financial management company”; interestingly, the websites using that term all appear to be scams.
Given that the Avis entities are not regulated, this paragraph is untrue:
The Financial Services Compensation Scheme does not apply to unregulated providers.
Many of the fund’s investments are into supposed nanoparticle production by Avis companies, and there’s a nanoparticle catalog on the website dating from 2017. On the left, below, is one page from that catalog. On the right is a page from a 2013 nanoparticle catalog published by Skyspring Nanomaterials, Inc.
It’s a crude copy. They didn’t even change the fonts or shading.
It therefore appears likely that the web of fictitious companies was created as part of an investor fraud..
We have not been able to determine if the fraud was successful. They applied for a LEI (the “legal entity identification” number a company needs to acquire securities). There are suggestions that those running this operation tried, and failed, to register as a bank in Zimbabwe (but we do not know how reliable those reports are). An archived website shows what looks like a fake portal for “Avis Bank”, and there is a discussion on an internet forum where someone says they considered signing up for services from Avis. An online website claims that the Avis entities and individuals are linked to a series of frauds – we cannot verify if the information on the website is correct, and our attempts to reach the authors of the website were unsuccessful.
From 2020 to 2023, Avis operated a website claiming to help victims of fraud recover their funds (the website is down; that’s an archive link). The style of the website is very different from Avis, but its email domain records were the same. So this appears to have been a separate “line of business” for Avis.
Avis Capital, and many of the other companies, have recently failed to file accounts and/or confirmation statements on time. This may be a sign that the fraud has ended (successfully or unsuccessfully; we do not know).
Who is behind Avis Capital?
The owners
The directors of Avis Capital and many of the other companies are Gerda Maria Koenig (an Austria resident), Jairo Restrepo Chavez (a UK resident), Alfred Schedler (an Austria resident) and Rosemarie Schell (Austria resident).
The links in the previous paragraph are to the individuals’ entries in the Paradise Papers, which show them to be owners of a Maltese company called Avis Global Energy Ltd. Ms Schell has a LinkedIn page describing her as “Director Controller & Ambassador of the Avis Global Green Energy Fund, Avis Global Energy & Avis Global Humanitarian Foundation”. Aside from that, we have no information on these individuals.
The “person with significant control” of Avis Capital Limited is said to be Ms Koenig, both directly and via Avis Global Energy Ltd.
We wrote to Avis Capital asking for comment and received this:
We then heard nothing further.
The facilitators
The registered office for Avis Capital and the other Avis companies is 102 Acre Lane in Brixton, which is an estate agent, Technoestates. One of the two directors of Technoestates Ltd is Andrew Restrepo Oviedo. Mr Oviedo is also a director of Avis Fintech PLC (the company with £100m of (likely) fictitious cash on its balance sheet), and a minority shareholder in Avis Capital’s parent company, Avis Global Energy Ltd.
Mr Oviedo owns a separate company called Tabono Corporation Limited. There are two directors: Andrew Restrepo Oviedo and Jairo Restrepo Chavez, who is a director of Avis Capital and most of the other Avis companies. Given the coincidence of names, and the Spanish custom of the father’s surname becoming a child’s first surname, it may be that Andrew Restrepo Oviedo is Jairo Restrepo Chavez’s son.8
We wrote to Mr Oviedo via Technoestates asking for comment; we didn’t hear back.
We don’t know how involved Mr Oviedo is in the Avis companies; at a minimum he is the director of a company which has filed false accounts, and has missed obvious signs of criminality in that company and the many others that use his office as a registered address. It is also possible he is a victim – particularly if he paid cash for the worthless Avis Global Energy Ltd shares.
An ICAEW-regulated accounting firm called RMR Partnership LLP provided company secretarial services, and a registered office, to Avis Capital (and other Avis companies) from 11 June 2020 to 24 August 2023 (either through the LLP or via one of their partners, Ragen Amin).9 It was during this period that Avis Capital Limited filed unaudited accounts claiming implausibly large asset holdings, and repeating balance sheet entries from one year to the next. An accounting firm should have realised these accounts were false, and that they should have been audited.
Mr Amin also appears to have acquired five million shares in Avis Capital’s parent company, Avis Global Energy Ltd. If he paid money for these shares, it may be that he is a victim of the fraud.
We wrote to RMR asking for comment; we didn’t hear back.
We don’t know how involved RMR and Mr Amin were in the Avis companies. At a minimum, an accounting firm was the company secretary of companies that filed obviously false accounts, missed obvious signs of criminality, and in acting for what appears to be a criminal enterprise, may have breached anti-money laundering rules.
Before RMR Partnership LLP’s involvement, the company secretary to Avis Capital and other Avis companies was Derek Williamson, a forensic accountant who runs Williamson Consultants Ltd. Mr Williamson was appointed in September 2018 and resigned in May 2020.
We asked Mr Williamson for comment – he sent us the following reply:
The statement that Avis Capital’s balance sheet was “merely issued share capital” is not correct. The accounts filed with Companies House in 2019 when Mr Williamson was company secretary, show £10bn of shares issued for £10bn cash. If Mr Williamson had checked the 2017 statement of capital, he would have seen that the shares were stated to be issued for cash. We would expect a forensic accountant to have understood this.
So again, an accountant appears to have missed obvious signs of criminality, and may have breached anti-money laundering rules. On Mr Williamson’s account, he has responded to subsequent signs of improper behaviour, although we are unconvinced that “chasing the company” is a sufficient professional response to the situation.
Mr Williamson didn’t reply to further enquiries from us; we therefore don’t know who the “accountant” was, or who “Mr H Konig” was. It may have been this individual: H K Koenig, “a pivotal member of the Board of the AVIS Umbrella”, who was jailed for fraud in Austria in the 2000s.
The PDF metadata for the fund memorandum shows the author as “Helmut Koenig”.
What offences have been committed?
The failure by Avis Capital to file audited accounts means the directors committed an offence under section 451 of the Companies Act. There’s a defence where the directors can show they took all reasonable steps to file accounts; that seems unlikely to be relevant in this case.
There is also a general offence of delivering false documents and/or making false statements to Companies House without reasonable excuse. The company itself and its directors are liable.
It is an offence under FSMA for a person to claim to be authorised by the FCA when they are not. It is also an offence to market regulated financial products when not authorised.
What should Companies House have done?
Avis Capital explicitly uses its Companies House entry as evidence that it is a substantial business. We expect many unsophisticated investors would take Companies House accounts at face value. That is why it’s so important that Companies House maintains the integrity of its records.
It has always been a criminal offence to knowingly file false accounts or other documents with Companies House. Historically, these rules were almost entirely unenforced. We are aware of only one successful prosecution; it involved someone making prominent politicians directors without their knowledge. This gives the unfortunate impression that company law breaches will only be prosecuted when they affect prominent individuals.10
Since last year, Companies House’s role has been expanded – its statutory objectives include ensuring the integrity of the register, and preventing companies from carrying on unlawful activities. Companies House now has wide powers to correct information and serve binding information requests on directors. It says it’s acted against 75,000 companies.
These powers should have been used in this case. Avis Capital and the related companies raise numerous red flags that should have triggered action:
- It is technically straightforward to automatically flag companies with anomalously large balance sheets, and submit them for manual review. Clearly Companies House doesn’t do this.
- It would also be straightforward to flag companies with large balance sheets and turnover which aren’t filing audited accounts.
- Avis Capital’s stated areas of business are: “banks”, “financial leasing”, “mortgage finance”, “securities dealing”. These would require a banking licence and/or regulatory authorisation – which Avis Capital doesn’t have. It would be straightforward for Companies House to flag companies whose stated activities conflict with their regulatory status. It would be equally straightforward for the FCA to scrape this information from the Companies House API (the interface that lets computers easily access the Companies House database).
- We identified Avis Capital by looking at our automated webpage showing PLCs that failed to file accounts on time. Companies House should be able to do this in a much more sophisticated and efficient manner.
But the most important failure is a failure to enforce the rules.
If blatant abuses like this were routinely identified and prosecuted, then we’d no longer see fraudsters (and worse) exploiting UK company law.
What should happen next?
We believe the information in this report provides enough basis for a criminal investigation into those behind Avis Capital. There have been flagrant breaches of company law and regulatory law. We hope the relevant authorities will take action.
If a case like this can’t be prosecuted, then the offences in the Companies Act may as well not exist.
Many thanks to the accountants and forensic accountants who assisted with this report, particularly P and J. Thanks to V for company law input and to K for research and review.
Footnotes
The accounts say the directors were satisfied the audit exemption in section 477 of the Companies Act applied. Section 477 provides an audit exemption for “small companies”. To be a small company you must satisfy two of the following three tests: fewer than 50 employees, turnover not more than £10.2m, balance sheet not more than £5.1m. Avis Capital Limited has balance sheet and turnover well in excess of these figures. It should have filed audited accounts. Indeed Avis Capital isn’t a “medium-sized company” either – to be a “medium-sized company” you must satisfy two of the following three tests: fewer than 250 employees, turnover not more than £36m, balance sheet not more than £18m. ↩︎
The accounts for previous years are also suspicious. Avis Capital Limited started out in 2017 with £10bn cash in the bank from its shareholders. The statement of capital filed by the directors shows 10 billion shares subscribed, for £1 each, with zero unpaid. It is very strange for a company to just put £10bn in the bank and do nothing with it.
The company’s accounts were exactly the same in 2018. Even a 1% return would produce £100m each year; any commercial business would expect a much higher return than that. Yet there is no sign of any income at all, or any tax or expenses.
There was an injection of £23.7bn of debt in 2019, but again the company just sat on the cash for two years, with no change in the balance sheet. The 2019 accounts also rewrote history so that the £10bn in previous years became an amount owed to the company. Perhaps they were claiming the £10bn of shares were not paid up, but the return of capital documents say that they were.
And the “cut off” 2020 balance sheet columns in the 2021 accounts completely contradict the actual 2020 accounts. ↩︎
The Avis Capital homepage shows the same registered address as we see on Companies House, so there’s little doubt this is the same company. ↩︎
We asked the Avis Budget Group for comment; they have not responded. ↩︎
Some people we spoke to thought it might be money laundering. We don’t believe that’s likely. The aim of money laundering is to take “dirty” money and place it into the financial system in a way that ends up looking like “clean” money. So, for example, setting up what looks like a legitimate business, and intermingling the “dirty” money with the “clean” profits of the real business. The Avis companies don’t look like legitimate businesses and don’t appear to have any legitimate income. ↩︎
The call option also refers to “Central European Time (London Time)”. Other documents are said to be subject to “United Kingdom law” (which does not exist; the law of England and Wales is different from the law of Scotland or Northern Ireland) and refer to “state and federal courts located in the United Kingdom”. The fund memorandum refers throughout to a “tax treaty” without ever saying which treaty is means, or why it a tax treaty relevant. The document uses the term “tax treaty qualifying shares” (which is not a term of art) and says, very optimistically, “An investment in the Fund is expected to benefit from the tax advantages offered generally from governments”. There are many more oddities, all of which suggest the documents may have been plagiarised from real legal documents. ↩︎
In the UK, tax relief is available for “venture capital funds” investing in small companies; the Avis companies are (supposedly) much too large to benefit from this. ↩︎
This is a very obvious point, which we’re embarrassed to have missed in the first published version of this report. Thanks to the many people who wrote pointing it out. ↩︎
RMR’s registered office, Vyman House, is named in the fund memorandum and other documents on the website; it’s also listed in the “Avis Bank” YouTube video. ↩︎
A prosecution of Sanjeev Gupta was recently instigated; again, it seems only the highest profile cases are prosecuted. ↩︎
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Two clicks to uncover fake companies on Companies House
![Data table showing Companies House records for several entities registered under banking SIC codes, with each company name circled in pink: Company Name | Company Number | Dormant | SICs | Cash | Item 1 | Value 1 | Item 2
[IS]LAMIC WORLD ECONOMIC COOPERATION ORGANIZATION LTD | 12112787 | Yes | 64110 - Central banking, 64191 - Banks, 64304 - Activities of ope..., 66300 - Fund management a... | 499,500,000,000 | CalledUpShareCapitalNotPaidNotExpressedAsCurrentAsset | 499,500,000,000 | NetAssetsLiabilities
AVIS CAPITAL LIMITED | 10465466 | Yes | 64191 - Banks, 64910 - Financial leasing, 64922 - Activities of mor..., 64991 - Security dealing ... | 24,404,296,829 | PropertyPlantEquipment | 128,166,038 | InvestmentsFixedAs
AVIS GLOBAL GREEN ENERGY FUND LTD | 11531289 | | 64191 - Banks, 64910 - Financial leasing, 64922 - Activities of mor..., 64991 - Security dealing ... | 19,082,266,881 | NetCurrentAssetsLiabilities | 19,082,266,881 | TotalAssetsLessCurrentLiabilities
GOOD LUCK GRANT LTD | 06903991 | Yes | 63990 - Other information..., 64110 - Central banking, 64191 - Banks, 74909 - Other professiona... | 9,263,512,047 | CalledUpShareCapitalNotPaidNotExpressedAsCurrentAsset | 80,000,000,000 | NetAssetsLiabilities
CREDIT LONDON LIMITED | 08275923 | | 64191 - Banks, 64301 - Activities of inv..., 66300 - Fund management a... | 648,548,152 | CurrentAssets | 648,548,152 | NetCurrentAssetsLiabilities
SAVINGS UK LTD | 12368272 | Yes | 64191 - Banks, 64301 - Activities of inv..., 64922 - Activities of mor... | 100,000,000 | | |](https://taxpolicy.org.uk/wp-content/uploads/2025/01/Screenshot-2025-01-31-at-22.49.54.jpg)
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