What is a Family Investment Company?
A Family Investment Company (“FIC”) is a company in which the shareholders are family members, often from different generations. FIC’s enable families to pass UK assets out of their individual estates for inheritance tax purposes, whilst retaining control or passing control to professional directors to manage the company. FIC’s also provide asset protection. … more
South Africa, currently, hits the headlines for the ‘wrong’ reasons but it remains a jurisdiction where investment, in the correct manner, can be attractive.
The South African economy offers a diversity of sectors and industries. It has a modern and extensive transport infrastructure and labour costs are priced competitively.
These factors, together with the country's significant natural … more
IN553 The Madeira (Portugal) Free Trade Zone - What Tax Benefits Does It Offer And Substance Requirements
The Madeira archipelago is part of Portugal and is located in the Atlantic Ocean, 978 km southwest of Lisbon.
During the past decade, Portugal has taken several steps to enhance its attractiveness to international business and high net worth individuals. Partially thanks to the Non-Habitual Residents tax programme implemented in 2009 and the Golden Visa residency programme introduced … more
Nevis is a leading international Caribbean financial centre with a good reputation and excellent standards.
The jurisdiction of St Kitts & Nevis offers options in terms of international companies, private trustee companies and international trusts and foundations. It also offers an attractive passport scheme (recipients do not need to reside in St Kitts & Nevis), which is of … more
IN550 - Visas Available To Non European Economic Area (EEA) Individuals Allowing Them To Work In The UK
There are a number of visas, enabling non-EU individuals to live and work in the UK, that are less well known than the Start-up visa, Innovator visa, Tier 1 (Entrepreneur) Visa (closed to new applicants since 29.03.19), and the Tier 2 (General) Visa.
This article considers these options, which include: ‘Representative of an Overseas Business Visa’, ‘Tier 2 Sponsor Licence’, ‘Van … more
IN549(R) - КЛЮЧЕВЫЕ ПЕРСОНАЛЬНЫЕ ПОДОХОДНЫЕ НАЛОГИ И ПОТЕНЦИАЛЬНЫЕ ПРЕИМУЩЕСТВА ДЛЯ НЕ ДОМИЦИЛИРОВАННЫХ РЕЗИДЕНТОВ СОЕДИНЕННОГО КОРОЛЕВСТВА
Ряд стран предлагают режимы «налогообложения на основе перечисления, чтобы заинтересовать богатых людей в переезде из других стран, таких как Россия. Эти люди известны как «не домицилированные резиденты». Проще говоря, не домицилированный резидент - это человек, который не живет в своей стране «гражданской принадлежности».
Режим перечисления в Соединённом Королевстве является особенно привлек … more
A number of countries offer ‘remittance basis of taxation’ regimes to attract wealthy individuals to re-locate from other countries, such as Russia. These individuals are known as ‘non-doms’. Very simply expressed a non-dom is an individual not living in his/her country of ‘origin’.
The UK remittance regime is a particularly attractive example and although the rules have changed … more
Over the past decade, Malta has consolidated its status as an international, Mediterranean centre of maritime excellence. Currently Malta has the largest shipping register in Europe and the sixth largest in the world. In addition, Malta has become a world leader in terms of commercial yacht registration.
In order to avoid the risk of shipping companies relocating or flagging to low-tax countries … more
The Maltese Government introduced modifications to the remittance basis of taxation on 1 January 2018.
Malta offers an extremely attractive remittance basis, whereby a resident non-domiciled individual is only taxed on foreign income if this income is received in Malta or is earned or arises in Malta.
A Tax Change for Resident Non-Domiciled Individuals
Changes, introduced at the … more
IN545 - Malta's Notional Interest Deduction Regime - Which Types of Company are Most Likely to Benefit?
Malta introduced the Notional Interest Deduction Regime (NID) on 1 January 2018. On 8 August 2018, the Guidelines in relation to NID were updated, in particular the treatment of NID between related companies.
What is NID?
NID is an innovative way in which companies can, in the correct circumstances, reduce their tax liabilities. This option is of greatest interest to companies with large equity … more
The EU Code of Conduct Group (Business Taxation) (“the COCG”) have been working with the Crown Dependencies (Guernsey, Isle of Man and Jersey) to review ‘economic substance’. The EU Code Group concluded that the Isle of Man and Guernsey were compliant with most of the EU principles of good tax governance, including the general principles of “fair taxation”. However, one area that raised concern … more
The Island of Guernsey offers Private Clients confidence in relation to the preservation, protection and growth of their wealth.
Guernsey is a well regulated jurisdiction situated in Europe, between the United Kingdom and France, with excellent travel links to both countries. It is a tax neutral, politically stable jurisdiction with an excellent reputation and a network of multi-jurisdictional … more
IN542 - The Maltese Parliament is Putting in Place the Foundations to Become the 'Blockchain Island'
Malta has, for several decades, been a country committed to new technologies and to welcoming investment in such sectors.
With blockchain it is no different.
At the end of June 2018, the Maltese Parliament unanimously approved three Bills:
The Virtual Financial Assets Bill.
The Technology Arrangements and Services Bill.
The Digital Innovation Authority Bill.
Each of these establishes … more
IN541 - Key Features of the New Double Tax Agreements between the UK and Guernsey, and the UK and the Isle of Man
At the start of July 2018 three new Double Tax Agreements (DTAs) were announced between the UK and the Crown Dependencies (Guernsey, Isle of Man, and Jersey). The three DTAs (from each of the islands) are identical, which was a key aim of the UK Government.
Each of the DTAs cover clauses relating to Base Erosion and Profit Shifting (’BEPS’) and they comply with new international tax standards, … more
The past few years have seen dramatic changes to the taxation of UK residential property for both UK and non-UK residents. Detailed below is a summary of the current position (as of June 2019).
It is important that existing structures (particularly those with foreign company ownership) are continually reviewed to ensure that the anticipated benefits of such structures remain … more
Tax on Rental Profit
Overseas investors who are not tax resident and do not carry on a trade in the UK are only liable to pay basic rate income tax (currently 20%) on rental profits during their period of ownership of a UK commercial investment property.
To achieve the favourable tax treatment outlined above, it is important to use an offshore company to acquire the UK property and that … more
IN536 - Advantages of Cyprus Foreign Interest Companies - Including the Right for Employees to Reside in Cyprus
Background and the Cyprus Permanent Residence Scheme
Cyprus offers a Permanent Residence Scheme whereby individuals are granted permanent residence by acquiring property in Cyprus with a minimum value of €300,000. The Dixcart office in Cyprus can provide comprehensive details regarding the Cyprus Residence Scheme.
This programme is proving popular but is not always appropriate as individuals … more
IN538 - Imminent Introduction of the Portuguese Tonnage Tax Scheme for Ships - What benefits will it offer?
The Portuguese tonnage tax and seafarer scheme was approved by the European Commission on 6 April 2018, in line with EU State aid rules, in particular the Guidelines on State aid to maritime transport. The Portuguese measures will enhance the competitiveness of the Portuguese shipping sector and, simultaneously, protect know-how and jobs in the EU maritime transport sector.
The law proposal had … more
IN535 - Consideration of the Jurisdiction of Nevis for the Control and Management of Companies outside the EU
The Requirement for Substance
In recent times a number of leading European countries have sought to limit the use of holding or associated companies outside the EU.
The main reason given has been the lack of real substance being demonstrated in the countries outside the EU.
A Workable Solution to the Problem
Advantages continue to exist through the use of holding companies outside the EU. … more
HN - Three Bills on ‘Distributed Ledger Technology’ (relating to Crypto Currency and Bitcoin) have been Approved by the Malta Parliament
On 26 June 2018, the Maltese Parliament unanimously approved three Bills.
The Virtual Financial Assets Bill -which provides regulation on virtual currencies and initial coin offerings (ICO)
The Technology Arrangements and Services Bill - which is concerned with the registration and certification of technology service providers
The Digital Innovation Authority Bill– which will establish the … more