Family investment companies are becoming increasingly popular as an alternative to trusts for wealth, estate and succession planning.
Why has the use of Family Investment Companies Grown?
Their use has grown significantly in recent years, particularly in instances where it is difficult for individuals to pass value into a trust, without being liable to immediate tax charges, but there is a … more
The jurisdiction of Guernsey offers a very pleasing environment to live in as well as very attractive personal and corporate tax regimes.
The island of Guernsey is the second largest of the Channel Islands, which are situated in the English Channel close to the French coast of Normandy.
Guernsey – a Tax Efficient Jurisdiction
Guernsey is a leading international financial … more
Trust structures are generally associated with estate and succession planning for private client engagements, because of the advantages and safeguards that a well-structured trust can provide.
Use of a Trust as Part of Corporate Processes
Trusts, however, can also play an important role within corporate transactions. Consider the planning phases leading up to an initial public offering (IPO), … more
The Maltese Income Tax Act exempts royalties, advances and similar payments arising from copyright, from tax.
Exemption in Respect of Certain Copyright Income
The income tax exemption with respect to royalties received from certain types of ‘copyrightable’ intellectual property, in relation to; books, film scripts, music and art.
The Income Tax Act exempts royalties, advances and similar … more
The location of a holding company is an important consideration in any international structure where one of the objectives is to minimise the tax charged on the income flow.
Beneficial Characteristics for the Location of an International Holding Company
Ideally the holding company should be resident in a jurisdiction which:
Has a good double tax treaty network, thereby minimising … more
INSWT Switzerland: Asset Protection, Double Taxation Agreement and an Attractive Location for Residence
What does Switzerland Offer Businesses, Individuals and Families?
Located in the centre of Europe
Economic and political stability
A well respected jurisdiction with an excellent reputation
Most ‘innovative’ country in the world for nine consecutive years
Lengthy history of expertise in finance and business
Premier destination for international investment and asset protection
High regard … more
Threats and opportunities have always existed and never more so than in this rapidly changing world.
Many countries are experiencing significant political and economic change. The jurisdiction of St Kitts & Nevis provides an opportunity for individuals to hold a second passport, even if the immediate intention is not to relocate to the Caribbean.
Key Benefits Offered By Holding a St Kitts & … more
The EU Council’s ‘base erosion and profit shifting’ (BEPS) action plan defines the requirements to be met, by jurisdictions wishing to maintain low tax regimes for businesses undertaking ‘specified’ activities, in order to demonstrate that they have sufficient substance in that particular jurisdiction.
Requirements include; ‘core income generating activities’ must take place in the … more
On 30 October 2019, the Ukraine ratified changes to two Double Tax Treaties (DTAs), the treaty with Cyprus and the treaty with the UK, respectively.
Once the appropriate formalities have taken place in the reciprocal countries, these treaties are expected to come into force at the start of January 2020.
Ukraine: Cyprus Treaty
The key changes are:
A reduction in the withholding tax for … more
КАК ШВЕЙЦАРИЯ МОЖЕТ ПОМОЧЬ ЗАЩИТИТЬ АКТИВЫ В УСЛОВИЯХ РАСТУЩЕЙ ГЛОБАЛЬНОЙ НЕСТАБИЛЬНОСТИ
Швейцария - невероятно привлекательное государство для международных компаний и физических лиц с крупным частным капиталом, которые ищут экономической и политической стабильности.
Причины, по которым Швейцария выигрывает по сравнению с другими странами
Политическая, финансовая, социальна … more
Каковы возможности переезда физических лиц в Швейцарию, и каковы варианты их налоговой базы?
Многие жители других государств решают переехать в Швейцарию из-за её высокого качества жизни, здорового и активного образа жизни, и прекрасных условий и возможностей как для трудовой, так и для предпринимательской деятельности.
Благодаря своему местоположению в самом сердце Европы … more
When Might You Consider Using a Will Trust?
Will Trusts can be used to protect property and assets within an estate.
They can be particularly appropriate to provide gifts and inheritance for children from previous relationships and to leave assets to a vulnerable or disabled person.
What are Other Potential Uses of Will Trusts?
Will Trusts can also be used for the following: … more
Angola is one of the fastest growing economies in the world. Additional opportunities are available for companies established in Portugal due to implementation of double taxation provisions and the increased certainty that this brings.
One year after its approval, the Double Tax Agreement (DTA) between Portugal and Angola finally came into force on the 22nd of August 2019. … more
The Malta Financial Services Authority (MFSA) has published its Annual Report and Financial Statement for the year 2018. It presents an overview of the activities and work carried out by the MFSA, together with details about the industry’s performance and explains the Authority’s vision for the coming years.
Despite a challenging and highly competitive environment, in 2018, the Maltese financial … more
The addition of Shaun Drake to the Guernsey office has enabled Dixcart to provide a new suite of services to listed (or public) companies that trade on worldwide stock exchanges. Shaun is a professional company secretary with 20 years of listed company experience with companies trading on stock exchanges in the UK, Canada, USA and Australia. He presently acts for a number of listed … more
Malta – Full Imputation Tax Regime
Malta’s competitive tax regime is based on a full imputation system. Tax on the profit paid by the company distributing dividends, is made available to the shareholder as a tax credit, to avoid double taxation on the same income (for the company and subsequently for the shareholder).
A shareholder receiving profit dividends can request a tax refund on those … more
Malta published new Patent Box Regime (Deduction) Rules in August 2019. The rules apply to relevant income derived from qualifying intellectual property (qualifying “IP”) as from 1 January 2019.
Qualifying Intellectual Property
Qualifying IP is defined as:
a patent or patents, whether issued or applied for (if applied for it assumes the patent is granted);
assets for which protection … more
On 3 May 2019, Portugal introduced amendments to Portuguese Taw Law, in accordance with the European Union (EU) Anti-Tax Avoidance Directive (ATAD). ATAD provides a set of anti-tax avoidance provisions across EU Member States. Provisions include:
Controlled Foreign Company (CFC) rules – to deter profit shifting to a low, or zero tax country
Exit Taxation – to prevent companies … more
The three Mediterranean countries of Cyprus, Malta and Portugal each offer attractive residence and citizenship programmes. This Article details the different criteria that are applicable and who the different programmes are available to.
Permanent Residence Permit
Malta Residence and Visa Programme
Any Jurisdictions … more
Malta is an attractive and progressive jurisdiction for company incorporations. Located within the EU, it is introducing new laws and regimes, on an on-going basis, to consolidate this position. New laws include ‘New Consolidated Group Rules,’ introduced in May 2019, and new ‘Patent Box Regime Rules,’ implemented in August 2019.
NEW CONSOLIDATED GROUP RULES
Malta Full Imputation Tax Regime … more