Roman Abramovich could owe UK £1bn in unpaid tax

Tax expert Rita de le Feria told the BBC that evidence a UK resident, such as Mr Shvidler, was taking “strategic big decisions” on the hedge fund investments was a “clear indication” the huge profits should have been taxed by the UK.

“I think this is a pretty big smoking gun. That would be, again, strong evidence that the effective management of the company was not taking place in the BVI,” she said.

Mr Shvidler’s lawyers said there can be “no question of Mr Shvidler, either knowingly or negligently, being involved in an unlawful scheme to avoid paying tax”.

Lawyers for Mr Abramovich said that in addition to the advice he obtained over his tax affairs, he “expects that similar advice was sought” by those with responsibility for running companies related to him.

The leaked documents also reveal how large amounts of the untaxed profits from Mr Abramovich’s hedge fund investments passed through a network of the oligarch’s companies before flowing into Chelsea FC.

The hedge fund investments flowed back into his companies in the BVI and then into Keygrove, their parent company.

Keygrove then loaned out money to other companies in Mr Abramovich’s network, which in turn lent money to Camberley International Investments Ltd – a company set up to bankroll Chelsea FC.

By 2021, when Chelsea won the Champions League, Club World Cup and UEFA Super Cup, hundreds of millions of dollars in loans to the club could be traced back to companies benefiting from Mr Abramovich’s untaxed hedge fund investments.