Trojaan then made use of Dutch “tax adjustments”, as company accounts described them, to pay tax at much lower rates than would have applied elsewhere. Trojaan paid dividends totalling €113.68 million between 2013 and 2017 to a Luxembourg company, Kilbroney Investments, part of the Goodman group with a €792 million balance sheet in 2020.
In separate 2012 transactions, Trojaan lent €566 million to other ABP companies, €400 million interest-bearing and the rest interest-free. Borrowers included the Irish entity ABP Foods, which received €134 million at the Euribor benchmark interest rate plus 4 percentage points.Such loans are profitable for Trojaan because it can borrow for free from other ABP companies.