Why is HMT’s charging investment fund linked to Jersey?
Zouk Capital explains its links with ‘Ssh Limited’ and its management of the CIIF
Hello, I’m Tom Riley, and welcome back to The Fast Charge, a British EV newsletter.
Top story today… The manager of a £420m public-private fund, which has backed numerous UK EV charging networks, is based offshore in Jersey. I ask why?
Elsewhere… Bentley brings out a good-looking concept car, one in four new registrations are electric, and even the new Pope has gone electric. The power of Christ compels you!
Finally, if you’re attending Goodwood tomorrow, do drop me an email. More generally, if you have any comments or feedback, please reply to this email or message me on LinkedIn.
Why is HMT’s charging investment fund linked to Jersey?
Headline: A £420 million public-private fund set-up in 2018 to invest in EV charging networks is based in Jersey; a country known for good butter, decent potatoes and, in the most part, a long history of financial skullduggery.
Background: The fund in question is the Charging Infrastructure Investment Fund - often simply shortened to ‘CIIF’. It was established in 2018 under Theresa May’s government, having first been announced by the Chancellor in 2017. The government’s aim was to partner with the private sector to “catalyse the rollout of electric vehicle charging infrastructure”. Following a Treasury request, Zouk Capital, an infrastructure and private equity fund manager, was appointed fund manager.
How much? Right at the start, the UK Government provided Zouk about £200 million. This was matched with money Zouk raised from private investors.
What’s Zouk achieved? Arguably, it has achieved a lot in the years since. The £420m CIIF pot of money has been allocated by Zouk into several UK charging networks. Zouk was an early backer of InstaVolt (before a buyout in 2022), it’s provided £100m to the lamppost network Char.gy, £105m to the network Zest, £35m to Energy Park (who are installing chargers in flat blocks) and, alongside Liberty Global, have made investments into Believ.
However… If you look at the Companies House pages of all these companies, inevitably, their ownership ultimately all appears to track back to a company based in Jersey. Specifically, all these networks seem to be ‘significantly’ owned by the almost comically named entity ‘Ssh Limited’. It is Zouk’s parent company.
Now… I do not want to do down the work of these networks. This story isn’t about them at all. It’s purely about asking: why is a taxpayer public-private fund connected to an offshore company?
As some context, in the UK, I think most of us are familiar with Jersey. It is like a financial ‘Neverland’. Companies and individuals across the world use it to park and funnel their capital. The island does not have inheritance, wealth, corporate, or capital gains tax. It’s also got few obligations on businesses around transparency. It’s a haven for hiding, so much so that its very land mass reduces by half at high tide. There are 33,000 businesses registered on the island. An impressive feat, when you consider it’s only 9 miles long and 5 miles wide.
So, why has Zouk chosen Jersey? And, more importantly, why have successive British Chancellors been ok with it? Surely, it is not a great reflection on the UK as a place to undertake business.
To get to the bottom of this story, I wrote to Zouk to clarify the situation. I’m pleased to say they were happy to provide on-record responses; see what you make of them. The short version is they say all taxable activity happens in the UK…
The Fast Charge: Are any profits or management fees related to CIIF managed or booked through offshore entities, and if so, why?
Zouk spokesperson: “No. CIIF is an English Limited Partnership. All fund-related profits flow through this entity directly to its Limited Partners. Zouk Capital LLP, which is authorised and regulated by the FCA, is the appointed Fund Manager. It receives 100% of the General Partner Share (Management Fee), which is fully booked and taxed through UK-registered, onshore entities.”
TFC: How does Zouk respond to concerns that offshore ownership of a public-private fund might undermine trust in the CIIF’s accountability, given £200m originally came from the public purse?
Zouk: “We understand and share the importance of maintaining public trust in public-private partnerships like CIIF. All management fees, performance-related carry, and fund profits are routed through UK-registered and UK-taxable entities. SSH Limited, while incorporated in Jersey, is a passive holding company and does not impact the transparency or governance of CIIF. Prior to public investment, the fund structure underwent rigorous due diligence by HM Government and its advisers to ensure compliance with UK tax law, operational transparency, and fiduciary responsibility.”
TFC: Is this structure in place because the UK is a difficult place for business and registering profits?
Zouk: “No. The structure was not established to avoid UK regulation or tax. All profits, fees, and carried interest are received and booked through UK-registered, UK-taxable entities. SSH Limited’s Jersey registration reflects structural and historical considerations. It has no impact on tax transparency, regulatory compliance, or operational control.”
I don’t have the necessary degrees to explain to you what they’ve responded with really means. All I can say is, for me, it left open a ‘So why stay in Jersey’ question. In response to this follow-up, Zouk’s answer seemed to go slightly against the previous statements.
The Fast Charge: Why does Zouk keep its parent company in Jersey?
Zouk spokesperson: “Zouk’s parent company has been incorporated in Jersey since the group’s formation in 1999. At that time, Jersey was — and remains — a widely used and well-regulated jurisdiction for holding companies in the investment management sector.
“The Jersey entity (SSH Limited) acts solely as a non-operating holding company and does not receive any revenues or carried interest. All fund-related activities, including the receipt of management fees and performance-related income, are conducted through UK-registered entities that are subject to UK tax and FCA regulation.
“A restructuring of the group to move the parent company to the UK would risk creating unnecessary tax consequences without delivering any operational or economic benefit. It would not enhance transparency, change governance, or impact the UK tax treatment of Zouk’s activities.”
Zouk could have simply not answered my follow-up question and left it at the previous responses. Though in their helpfulness, I fear they’ve tripped up with that last line. To me, this is a firm saying they’d suffer tax consequences from a move, and basically telling me, ‘This is just how finance is done, mate’.
I was keen to see how HM Treasury felt about the arrangements, especially given they’ve signed it off. However, despite two phone calls with two different press offices, three confirmations they’d respond, five chase emails, and providing the department six working days to reply. As of 1pm on Wednesday 9 July, I have received nothing.
Read into that what you will. But I don’t believe Zouk’s last statement reflects well on UK Plc. Even more so for a government under pressure to balance the books.
Before we get into the news…
In my edition last week, paid members were able to download the Government’s internal ZEV mandate messaging pack. As promised, I have now made that edition accessible to all. So, if you’re interested in 22 pages of Whitehall lines to take about the recent consultation changes, you can access the doc below.
In the past week…
📊 Last week, Auto Trader published its latest update to its ‘Road to 2030 Report’. See it here. The key headlines are that 8 in 10 drivers are expecting another u-turn on EV sales targets. Likewise, based on current trajectories, Auto Trader estimates only 45% of new car sales will be electric by 2030.
📈 On a more positive note, the latest EV registration figures revealed that one in four car buyers is now going electric. According to New AutoMotive, this will mean carmakers will meet the ZEV mandate this year, given the flexibilities they have. Lovely bit of squirrel.
☝️ Talking of registrations, are the dog days over for Tesla? In the new data, it’s reported Tesla sold 7,719 units in June, up 14% from a year earlier, according to the SMMT. Read more.
🚘 While Tesla may be clawing back, one of the most interesting parts of the new data was that one in 10 cars that arrived in June were from China. This time last year, it was about half that. Read more. No doubt it will further grow, as this week Chery announced it would launch this year. Likewise, BYD’s luxury brand, Denza, will debut at Goodwood this week.
♿️ New research by Vauxhall reveals 38% of UK councils* do not have on-street chargers that have been adapted to suit the needs of disabled drivers or conform to British Standards Institution’s accessible charging standard, PAS 1899. *When they say councils, it is actually 111 of the 289 councils that responded. See results. Not to detract from the point, though, this is an important issue being left to fester. While I’d previously heard new guidance would be published this Summer, now the latest I’ve heard is it might not be until 2026. Mad.
😐 bp pulse has withdrawn from the workplace charging market in the UK, instead choosing to focus on ultra-rapid charging hubs and forecourt charging. Read more.
🧩 A survey of 1,600 people by charging network Jolt found 70% of people spend their public charging sessions for ‘me time’. Read more. Maybe charging apps should offer puzzle games or a crossword?
🔋 Talking of waiting around, the Cambridge company Nyobolt got some great coverage in the BBC this week. It was all about how it’s trying to enable EV batteries to be charged in under five minutes. Read more.
🏁 Bentley has revealed an electric limo concept that, dare I say it, looks rather yummy. Sadly, the name is atrocious - the ‘EXP 15’. Like many EV models, Bentley has fallen into the trap of trying to make the car seem modern by giving it a name better fit for a batch of special edition condoms. Very disappointing given the design inspiration. More on that below.
For this concept, it’s said Bentley has taken design inspiration from the century-old ‘Bentley Blue Train’ Speed Six model, which was famously raced against France’s Côte d’Azur train in 1930 by Woolf Barnato (then Chairman of Bentley and a renowned playboy).
The story goes that Woolf, while champagned to the nines in Cannes, made a £100 bet with friends that he could beat the ‘Blue Train’ back to Calais, and even reach the Conservative Club in London using his Speed Six before it even hit the platform. An original Top Gear race, if you will.
Amazingly, he did it. But when the French authorities heard about this from press reports, they were so angry they made a point of fining Woolf more than he’d won.
Bentley, you should call it The Woolf. You could even repeat the race for some PR!
🤔 Talking of London… Last night, the trade association ChargeUK hosted a Summer reception. I’d love to tell you what they’re up to. However, while I was invited to their last reception, this time I was not, so I have no idea. I did ask a week ago, alas, nothing was forthcoming. Maybe I’m on the naughty list? At least I hope so!
💸 Speaking of associations, according to the annual Road to Zero report, published by the British Vehicle Rental and Leasing Association (BVRLA), due to the falling used EV prices, many leasing firms are losing millions while EVs stay on their books or eventually get sold for a loss. Read more.
🛒 If you use an EV charger at Sainsburys up to 20 July and have a Nectar card registered, you may be in with a chance of winning one million points. Crikey. Read more.
🙏 Finally… Worried about EVs? Don’t be. Even the almighty’s main geezer on Earth, Pope Leo, is a beliEVer. According to Vatican News, he has just received two small vehicles.