Pays £149 million per year in unitary charges. Contract runs to 2048.
Payment is "first call" — legally paid before any clinical spending.
Barts closed 250 beds on the day the PFI hospital opened.
UK taxpayer funded
↓£149m/yr annual unitary charge (inflation-indexed, guaranteed)
Shell company controlling £1.1bn hospital build with just £500,000 equity.
Debt structure: £745.4m bonds + £250m EIB loan + £20m mezzanine.
SPV-level profits: part of £1.9bn extracted across 99 NHS PFI companies (2004–2021).
Internal loans at 7% average (vs 3.59% BoE base rate).
Director S. Sidhu also director of Innisfree Ltd (fund–SPV overlap).
UK corp tax at SPV level
↓Dividends + management fees flow upward
£26.3m turnover · £17.7m profit · £15.3m dividends paid (2024).
Manages £18.4bn capital across 58 PFI projects in 4 closed funds.
Holds 100% of Coventry, Derby, Sherwood Forest, St Helens. 50% of Barts.
PwC audits Innisfree and the Barts SPV (dual audit conflict).
Takes qualifying entity exemption — avoids cash flow and related party disclosures.
↓72% of shares held offshore
Holds 72.2% of Innisfree Group shares.
Received £47.4m of £66.2m total dividends (2006–2015) — routed offshore.
Jersey corporate tax rate for funds: 0%.
No public disclosure of ultimate beneficial owners behind the trust structure.
0% corporate tax
↕Meanwhile, a parallel channel
Sold £725m in NHS assets (2023–25).
Routes through Luxembourg Sarls.
Manager: InfraRed (80% owned by Sun Life, Canada).
Fees: £30.7m/yr regardless of trust outcomes.
GLIL/LPPI own 47.1% of Semperian (94 PFI assets).
NEST (⅓ UK workforce) joined GLIL 2021.
NHS staff pensions → GLIL → Semperian → profits from same trust's PFI charges.
The worker funds the extraction AND 'profits' from it.
Sources: Companies House filings (Innisfree Ltd 03039792, Capital Hospitals Ltd 05462470, Innisfree Group Ltd) · IPA PFI/PF2 Projects Summary Data (March 2024)
ESSU Research Report No. 8 (Whitfield, October 2016) · HICL Annual Report 2025 · NHS Trust Annual Accounts · CHPI (December 2024)