The UK could be perceived to have one of the most punitive inheritance tax regimes in the world. Individuals pay a 40% rate on the value of their taxable estate above a tax free allowance of £325,000. In the case of a married couple this tax free allowance can be passed onto a surviving spouse, which means that, following their death, the estate will enjoy a £650,000 tax free allowance. … more
There have been a number of changes to the taxation of UK property in recent years. The majority of these changes have been focused on residential property and have not affected commercial property.
Ongoing reductions in UK corporate tax, now 19% and moving to 17% in 2020, continue to make UK commercial property an attractive investment option.
The choice of holding structure used to … more
Many have asked “What are the implications caused by Brexit for the UK’s status as a premier jurisdiction for holding companies?”
Below we examine a number of the features that make a good holding company jurisdiction and consider the UK holding company offering both pre and post Brexit (as of December 2017).
Virtually all dividends received by a UK company, be they … more
On 8 September 2017, the second Finance Bill of 2017 was published. This confirmed that the previously announced policies, including amendments to the taxation of non-doms due to start on 6 April 2017, would be effective from that date.
In addition, further draft legislation, which will form part of a third Finance Bill, was published on 13 September 2017. This introduces new rules in relation … more
On 23 September 2017, the St Kitts & Nevis Government announced that a payment could be made to the Hurricane Relief Fund to acquire a passport. This is part of a new initiative under the St Kitts & Nevis Economic Citizenship Programme for the reconstruction of the Country following Hurricanes Irma and Maria. This programme is currently running until March 2018; although it is anticipated that it … more
What is a Foundation?
A Foundation is an incorporated legal structure that can be used to hold assets. As a concept, it is neither a Trust nor a company; however it has features of both. During medieval times, a Foundation was originally founded as an asset holding entity under Civil Law in continental Europe, whereas the Common Law vehicle has been, and still is, the Trust. Foundations were … more
The Maltese Budget speech of October 2017 proposed a number of changes, including modifications to the remittance basis of taxation in Malta.
Malta offers an extremely attractive remittance basis, whereby a non-domiciled individual is only taxed on foreign income if this income is received in Malta or is earned or arises in Malta.
Resident Non-Domiciled Individuals and Tax Changes … more
Malta introduced the Notional Interest Deduction Regime (NID) in October 2017. It comes into force at the start of the 2018 Maltese corporate tax year (1 January 2018).
What is NID?
NID is an innovative way for companies to reduce their tax liabilities. This option will be of greatest interest to companies with large equity balances.
NID allows companies to deduct a notional interest amount … more
IN495(P) -ST KITTS & NEVIS CIDADANIA POR PROGRAMA DE INVESTIMENTO: PAGAMENTO AO FUNDO DO FURACÃO - OPÇÃO DE INVESTIMENTO DE CUSTOS INFERIORES
Anúncio de setembro de 2017
O Governo de São Cristóvão e Nevis (St Kitts & Nevis) anunciou, a 23 de setembro de 2017, que, como parte do Programa de obtenção de Cidadania através do investimento em vigor em São Cristóvão e Nevis, uma doação agora poderá ser feita ao Fundo de Apoio a reconstrução do País devido aos efeitos dos Furacões Irma e Maria (Hurricane Relief Fund), recebendo o investidor … more
IN500 - The Option of a Passport to Ease Travel whilst an Application for Alternative Citizenship is Underway
There are several attractive residence schemes whereby non-EU individuals can obtain citizenship and the right to a passport in an EU country.
Two of the most popular EU programmes are the Maltese Individual Investor Programme and the Portuguese Golden Visa Regime.
A St Kitts & Nevis passport could provide a travel and if required, residence solution, whilst plans are being made to live … more
Malta as a jurisdiction, with it generous and effective corporate tax system, is positioning itself as a leading Blockchain technology hub, with many state led initiatives currently underway.
Earlier this year the Maltese Government implemented a National Blockchain Strategy aimed at capitalising on the current opportunities for Malta to become a global Blockchain and Cryptocurrency front runner. … more
UK tax resident, non-domiciled, individuals who are taxed on the remittance basis, are not required to pay UK income tax and/or UK capital gains tax on foreign income and gains, as long as these are not remitted to the UK.
It is, however, crucial to ensure that this tax benefit is properly claimed. Failure to do so means that any planning undertaken by the individual might be ineffective and he/ … more
An Alternative Investment Fund (AIF) is a collective investment which raises external capital from a number of investors with a view to investing it for the benefit of those investors. It does not need to be licensed as an Undertaking for Collective Investment in Transferable Securities (UCITS).
Alternative investments include hedge funds, managed futures, real estate, commodities and derivative … more
IN496 - What is a Guernsey Private Fund Structure and why are Family Offices Increasingly Using Them?
Why Guernsey For Private Fund Structures?
Guernsey is a leading domicile for funds, with more than 50 years of experience in the formation, administration and cross-border distribution of investment funds. It also offers a ‘lighter touch’ approach to Private Investment Structures (‘PS’), also known as Private Funds (‘PF’), which are ‘related party’ investment structures, particularly suitable … more
IN495(R) - ПРОГРАММА ПРЕДОСТАВЛЕНИЯ ГРАЖДАНСТВА СЕНТ-КИТСА И НЕВИСА ДЛЯ ИНВЕСТОРОВ: ВЗНОС В ФОНД ПОМОЩИ ЖЕРТВАМ УРАГАНА - ВАРИАНТ ИНВЕСТИЦИЙ С МЕНЬШЕЙ СТОИМОСТЬЮ
Информация на сентябрь 2017 года
Правительство Сент-Китса и Невиса заявило 23 сентября 2017 года, что в рамках экономической программы предоставления гражданства Сент-Китса и Невиса, теперь возможно внести взнос в Фонд помощи жертвам урагана для того, чтобы приобрести паспорт Сент-Китса и Невиса.
На данный момент, эта программа остается в силе до марта 2018 года, однако срок ее действия, скорее … more
IN495(S) - Programa De Inversión Para Obtener La Nacionalidad De San Cristóbal y Nieves: Pago Al Fondo De Ayuda De Huracanes – Una Opción De Inversión De Menor Coste
Comunicado de septiembre de 2017
El gobierno de San Cristóbal y Nieves anunció el 23 de septiembre de 2017 que, como parte del Programa Económico de Nacionalidad de San Cristóbal y Nieves, puede ahora realizarse un pago al Fondo de Ayuda de Huracanes para conseguir el pasaporte sancristobaleño.
Este programa estará vigente hasta marzo de 2018, aunque es probable que el plazo se prolongue. … more
IN495 - St Kitts & Nevis Citizenship by Investment Programme: Payment to the Hurricane Fund - A Lower Cost Investment Option
Announcement September 2017
The St Kitts & Nevis Government announced, on 23 September 2017, that as part of the St Kitts & Nevis Economic Citizenship Programme, a payment can now be made to the Hurricane Relief Fund to gain a St Kitts & Nevis passport.
This programme currently runs until March 2018, although it is anticipated that it is likely to be extended.
Hurricane Relief Fund Details … more
MAR: Recognition as an International Shipping Register
The recent publication of the 2016 Annual Report Paris MOU on Port State Control (PSC) has confirmed Portugal’s international shipping register (MAR) as highly rated in terms of quality and safety standards.
MAR is also “White Listed” in the 2016 Annual Report of the Tokyo MOU, which is one of the most active regional PSC organisations in … more
Advisers often need to guide clients on the most suitable jurisdiction to flag an owner’s vessel. Historically, advisers have preferred tried and tested jurisdictions, but this is starting to change, due to the increasing importance of jurisdiction perception, international transparency, time differences, different legal systems and growing costs associated with certain jurisdictions.
Criteria … more
The Cyprus VAT Department has issued various guidelines (2012, 2014 and 2015) which have made Cyprus one of the most attractive jurisdictions for yacht registration in the European Union.
Guidelines Issued in 2015
In April 2015 the Cyprus VAT Department issued a new circular reducing the applicable VAT payable on yacht lease payments to as low as 1.9%.
The reduced rates were made … more