35

Henri went on working on her tan for the rest of the morning while I sat in the shade complaining that it was far too hot in the midday sun even for mad dogs and Englishmen.

‘Would you like a cold drink?’ I asked, standing up.

‘Yes, please.’

‘Water or wine?’

‘Both,’ she said. ‘Together. I’ll have a spritzer. With some ice, please.’

‘Sounds lovely. I’ll have the same.’

I walked the few yards into the apartment and went into the kitchen to fix the two spritzers, but I didn’t go straight back outside. Instead, I went into the master bedroom and took out the packet of Henri’s board papers from the bedside drawer where she’d put them.

Atherton, Bradley and Partners, Attorneys at Law was printed across the top of an accompanying letter that gave the details of the Christmas Eve meeting to be held at their offices. I found a notepad and copied down the address and telephone number. I tore off the sheet and put it in my pocket.

I skimmed through the stack of papers, looking for any financial accounts that might indicate the identity of the company’s accountants, but there was nothing. In fact, the board papers appeared to be very sparse for the main annual meeting of the directors of such a big organization. Henri had clearly been right when she said that most of the discussion and decisions were taken at the management board level and the main board was only there to rubber-stamp their findings.

I glanced briefly at the documents pertaining to the sale of the Hong Kong end of the business. The amount of money being paid for it made me whistle. I reckoned the Reynard family would soon be moving further up the Sunday Times Rich List, some considerable way further up.

I put the papers back how I’d found them in the drawer and took the drinks out to Henri, who hadn’t moved an inch.

‘Lovely,’ she said, taking one of them. ‘Thank you.’

We clinked our glasses. How perfect was this?

I decided not to tell Henri that I intended to go home the following evening. I would make up some work-related excuse in the morning and then try to slip away before Martin even realized I had gone. I certainly wasn’t going to spoil our last wonderful day together in this paradise.


Stingray City was everything that Henri had made it out to be, with not a single street or building to be seen. This particular city’s blocks were nothing but water.

In the middle of North Sound, at least a mile from the nearest point of dry land, we stood waist-deep on a barely submerged sandbar while scores of stingrays swam around us, gliding back and forth between our legs like mini delta-winged bombers, their soft undersides caressing our skin like velvet.

By holding small pieces of cut-up squid we were able to make them follow our hands in circles in the water, even to swim right onto our outstretched arms to lie with their prominent staring eyes just inches from our faces.

A stingray had killed Steve Irwin, the Australian conservationist and broadcaster, and their very name implied danger. But here they were, acting like pets, playing with us and seemingly enjoying the experience as much as we were.

Our captain, the weather-beaten local from whom we had chartered the boat, told us that, more than fifty years ago when he was a young lad, the local fishermen used to bring their catch to the sandbar to clean and gut it, where the water was calm and they were able to throw the fish waste into the sea.

The stingrays would gather to feed on the fish scraps and soon the fishermen were organizing trips for locals to see them and Stingray City was born. And so it had continued, with both the humans and the stingrays apparently very happy with the arrangement.

‘This is now the most visited tourist attraction in Cayman,’ Henri said. ‘There would have been masses of boats and literally hundreds of people here earlier, all on organized tours from the cruise ships. It’s like Piccadilly Circus in the rush hour from about ten in the morning until about four in the afternoon almost every day of the year. Then they go back to their ships and sail away.’

I looked around us at the empty sea, with only our boat bobbing gently at anchor nearby.

‘It was a good call of yours to come later,’ I said.

It had also given me the opportunity to phone Atherton, Bradley and Partners, Attorneys at Law, and ask them who were the accountants for Reynard Shipping Limited. Not that it had been a satisfactory call.

‘I’ll put you through to Greg Sherwood,’ the operator had said.

‘And who are you, exactly?’ Greg Sherwood had asked when I’d repeated my request to him.

‘Just someone who wants to know.’

There had been a distinct pause from the other end of the line.

‘I am sorry,’ he’d said eventually. ‘Cayman law does not permit me to give out that information to persons not directly involved with the company.’

I had no way of knowing if he’d been telling me the truth or not. Either way, I would have to be satisfied with just writing to the company at their registered office. They could forward it to their accountants if they wanted.

Henri and I stayed on the sandbar a while longer, enjoying the stingrays, until the sun started dipping rapidly towards the western horizon. Then we climbed back on the boat and set course for the shore as the darkness descended across us like a falling blanket from the east.

Henri and I stood in the bow of the boat, in each other’s arms, and watched as the lights in the hotels and condominiums on Seven Mile Beach began to twinkle brightly.

‘It’s so beautiful,’ Henri said. ‘I don’t want to ever go home.’

Neither did I. And especially not five days earlier than originally planned.


The phone was ringing in the apartment when we arrived back just before seven.

Henri answered it.

‘We’d love to,’ she said. ‘Shall we meet you there?’ She listened. ‘OK. We’ll be ready.’

‘Who was that?’ I asked as she put the phone down.

‘Uncle Richard,’ she said. ‘He’s asked if we would like to go out to dinner tonight with him and Aunt Mary. There’s a new restaurant they want to try. They’re picking us up in an hour.’

‘Is Martin coming?’ I asked.

‘Uncle Richard didn’t say so. I got the impression it was just the four of us.’

Henri hurried into the bathroom to shower and change while I opened my laptop and logged on to the internet. I was still in the shorts and T-shirt I’d been wearing on the boat, but it would only take me a few minutes to change.

There was an e-mail from Quentin:

Jeff,

A few more thoughts about our friend Martin Reynard. I called a solicitor friend of mine who deals with tax affairs for offshore companies. He says the new rules on tax residency are catching out all sorts of people who thought they were safe and now find they’re not, mostly because of how the tax authorities are interpreting the UK ties rule in their new Statutory Residence Test. Some, who thought the new system meant they could stay in the United Kingdom for up to 120 days each year, are actually only allowed to stay here for 90, or even for only 45. There was also something else he said that might be of interest — it seems that some companies are also finding themselves in trouble because of a director inadvertently becoming UK tax resident.

Good luck, Quentin.

I typed ‘UK tax residency for companies’ into the internet search engine. The result was most revealing:

A company is generally treated as tax resident in the United Kingdom if it is either incorporated in the United Kingdom or, if not, if the boardroom control is exercised in the United Kingdom, or a majority of its board members are UK tax residents.

Reynard Shipping Limited was not incorporated in the United Kingdom. Martin had moved its registration to the Cayman Islands three years ago.

I could hear Henri singing in the shower.

I went quickly into the bedroom and looked again at the packet of board papers in the bedside drawer. They included the minutes of the last meeting, held in Singapore the previous September. The minutes recorded those board members present: Sir Richard Reynard (Chairman), Martin Reynard (Managing Director), Henrietta Shawcross, Greg Sherwood and Alistair Vickers. There had been no apologies for absence. So the Reynard Shipping Limited board of directors comprised just those five.

I knew from my earlier phone call that Greg Sherwood worked for Atherton, Bradley and Partners, the local Cayman lawyers, and I assumed that Alistair Vickers did as well. They were the two directors that Henri had said were there just to ensure the company complied with the local regulations.

Sir Richard and Henrietta both lived permanently in England.

A company is generally treated as tax resident in the United Kingdom if... a majority of its board members are UK tax residents.

As long as Martin was non-resident, a majority of the board members were non-resident, so the company was non-resident.

If, however, Martin had become a UK tax resident, even accidentally, then the company...

‘What are you doing?’ Henri said behind me in an accusatory tone that made me jump.

I turned around with the board papers still in my hands. It was far too late to put them back without her seeing.

‘Nothing,’ I said, smiling at her.

She did not smile back. ‘What are you doing with those?’ she asked, pointing at the papers, the accusation still clearly evident in her voice.

‘I just wondered who the other directors were,’ I said tamely.

‘Why?’

‘No reason.’

I could hardly tell her my true motive. I returned the papers to the drawer and pushed it shut.

She was not happy.

I had grossly invaded her privacy and she didn’t like it. Not one bit.

The doorbell rang.

I was relieved, thinking that it had got me out of a spot of trouble.

How wrong I was.

I opened the front door to find Bentley Robertson and Sir Richard Reynard standing there, and neither of them was in a friendly mood. They didn’t wait to be asked in, they just forced their way through the door as I backed away down the hallway. They closed the door behind them.

Henri came waltzing out of the bedroom wearing a bathrobe and with a towel turban on her head.

‘What’s going on?’ she said. ‘You said in an hour. I’m not ready.’ She pointed at Bentley. ‘And what the hell is he doing here? I’m not going anywhere with him.’ She was almost shouting.

‘Henrietta, be quiet,’ Sir Richard said, taking his eyes off me for only a fraction of a second.

Henri opened her mouth as if to say something more.

Her uncle held his hand up towards her. ‘I said, be quiet!’

She closed her mouth again.

‘Greg called me from Athertons,’ Sir Richard said. ‘Someone’s been asking questions about the company, and I reckon it’s Hinkley. I want to know why.’

‘He’s been asking me lots of questions about it as well,’ Henri said unhelpfully. ‘And I’ve just caught him looking through my board papers.’

‘Are you some sort of industrial spy?’ Sir Richard asked. ‘Who are you working for?’

‘I am not a spy,’ I said. ‘And you know damn well that I work for the British Horseracing Authority.’

‘So why are you asking questions about our company?’

I thought about Quentin’s advice and said nothing.

‘Go and pack your things,’ Sir Richard ordered. ‘You’re leaving.’

I looked at Henri but if I thought she was going to stand up for me, I was sorely mistaken. She turned away without looking at my face.

Sir Richard followed me into the bedroom and waited while I collected my things together and put them in my suitcase. It seemed to be the only thing to do.

‘Where am I going?’ I asked him, putting my wallet and passport in my shorts pocket.

‘Out of here,’ he said. ‘We will put you on the late Cayman Airways flight to Miami. After that, I don’t care.’

We went back to the others.

My laptop computer was open on the table and Bentley was studying the screen, which I’d carelessly left still showing the government website on company tax residency.

‘He knows,’ he said, looking up at Sir Richard. There was something about his tone I didn’t like.

‘You bastard!’ Henri shouted, coming up and standing right in front of me. I could see the tears in her eyes. ‘And to think I was falling in love with you when all you were interested in doing was spying on me. You make me sick.’

She hit me hard across the face with her open right hand, making my skin sting. I could taste the saltiness of blood at the corner of my mouth.

She turned away from me, walking over to the window facing the beach.

How I desperately wanted to go after her, to explain that it was not true, I was not a spy, my feelings for her were genuine, not fabricated — and I’d fallen in love with her too. Deeply.

But, for now, my best course of action was to get out and catch that late flight to Miami, and preferably before Martin turned up with alternative plans.

Say nothing and get out of there as soon as possible.

I should have followed my brother-in-law’s advice to the letter.

I was cross with myself for having been distracted by Henri. If those years in Afghanistan should have taught me anything, it was to know when to leave a situation, to get out before the shooting started. And yet I had delayed my departure to spend the day with a girl. And it had also been ill-considered on my part to call the lawyers. I should have waited until after I was safely away.

I went over to collect my computer and phone from the table.

‘Leave them,’ Bentley said. ‘You’re not taking those.’

‘They’re the property of the BHA,’ I said.

‘Then we’ll arrange to have them returned,’ he said, ‘once we’re satisfied there’s nothing on them about our company.’

Bentley closed the lid of my computer and put my iPhone in his pocket. Short of fighting him for them, there was nothing I could do.

I picked up my bag and walked out of the apartment without a backward glance. I couldn’t bear to look at Henri in such an angry state with me.

It was as much as I could do not to cry.


Sir Richard drove with Bentley sitting next to him in the front. I was in the back. None of us spoke.

I’m not sure how long it took me to work out that I was not on my way to the airport and the late flight to Miami. When we had arrived, the journey from the airport to the apartment had only taken ten minutes, and we’d already been going for much longer than that.

The lights of George Town receded behind us.

‘Where are we going?’ I asked with trepidation.

There was no reply.

The car slowed for some red traffic lights. Time to go, I thought.

As the car stopped, I reached for the door handle and pulled, but nothing happened. It was child locked.

‘Let me out,’ I demanded.

Bentley turned around to face me between the front seats.

He was holding a pistol and it was pointed directly at my heart.

‘How melodramatic,’ I said.

It was far from being the first time someone had pointed a gun at me, although the last time had been several years ago, in Afghanistan, but there was something about the smirk on Bentley’s face that sent a shiver down my back.

‘You’re a very difficult man to kill, Mr Hinkley,’ he said.

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