Grok replies to the prompt: What are the Shell Leaks Files?
“The Shell Files” (also referred to in reporting as Shell’s leaked transfer pricing documents or related Shell leaks) are a cache of confidential internal Shell transfer pricing reports and related materials that became public after a 2020 cyberattack on Accellion’s File Transfer Appliance (a managed file-transfer service used by Shell and many other organizations).
Dutch research group SOMO analyzed and published findings from these documents in a July 23, 2026 report titled The Shell Files: Exposing how corporations can use transfer pricing to avoid taxes. The files illustrate how Shell applied OECD transfer pricing rules (the “arm’s length principle”) to allocate profits across subsidiaries.
Key points from SOMO’s analysis
- Oil trading in the Bahamas: A Bahamian subsidiary with only 37 employees booked about $6.2 billion in profit (2018–2023) in a zero-tax jurisdiction. SOMO estimated that up to $5.6 billion of those profits might otherwise have been taxable in places such as Brazil, Nigeria, and the UK if profit-per-employee levels matched Shell’s European trading operations.
- Intellectual property / trademarks in Switzerland: Royalties were structured using different OECD-approved methods over time (including a “25% rule” earlier and later benchmarking), shifting income to Switzerland.
- Intra-group services in the Netherlands and UK: Large service operations in Shell’s home countries historically recorded little or no profit (often at cost). After tax-authority interventions around 2016–2017, Shell switched to benchmarking. SOMO modeled that applying typical commercial margins could have generated substantial additional taxable profits (and thus tax) in those countries.
SOMO argues the documents show structural weaknesses in the OECD framework itself—subjective judgments about functions/assets/risks, flexible benchmarking ranges, and company-produced documentation—that allow significant profit shifting while remaining formally compliant. The group advocates shifting toward unitary taxation with formulary apportionment (allocating global profits based on real economic factors such as employment, sales, and assets). Shell has stated that it follows OECD guidelines and denies engaging in illegal profit shifting.
Related context
Other Shell-related document disclosures exist and are sometimes discussed alongside or confused with these:
- Recent UK litigation documents (including ~27 redacted internal emails, audits, and presentations from roughly 2008–2014) examined by Amnesty International and partners in mid-2026. These concern Niger Delta pipeline integrity, maintenance, pollution risks, and potential decommissioning liabilities estimated in the billions.
- Earlier leaks and archives (e.g., Accellion/MOVEit-related personal data exposures, WikiLeaks cables on Nigeria operations, climate knowledge documents, and the long-running public archive of Shell materials maintained by activists John and Alfred Donovan).
The specific phrase “Shell Leaks Files” or “Shell Files” most directly points to the 2020 Accellion-sourced transfer pricing cache highlighted by SOMO in 2026. The underlying redacted documents and full SOMO report are available via SOMO’s site.
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