• 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

  • IN622 The Reassurance of Having a Second Passport

    Threats and opportunities have always existed and never more so than in this rapidly changing world.

    Many countries, including South Africa, 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 … more

  • IN619 Substantial Activity Requirements: The EU Council, OECD and Low Tax Jurisdictions

    Background

    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

  • IN621 Ukraine - Changes to Two Double Taxation Treaties

    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

  • IN620 An Important Guide: Moving to the United Kingdom

    Background 

    It is a very interesting time in the UK. A General Election is taking place on 12 December 2019 and until the results are known it is impossible to predict when Brexit will take place or even if it will take place.  

    Allowing for the current uncertainty, the UK remains an attractive destination for individuals to move to, for organisations and individuals to set up businesses in and … more

  • IN569 (R) Switzerland for Asset Protection in an Increasingly Challenging World

    КАК ШВЕЙЦАРИЯ МОЖЕТ ПОМОЧЬ ЗАЩИТИТЬ АКТИВЫ В УСЛОВИЯХ РАСТУЩЕЙ ГЛОБАЛЬНОЙ НЕСТАБИЛЬНОСТИ

    Общая информация

    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

  • IN582 (R) Moving to Switzerland and the Basis of Taxation

    Каковы возможности переезда физических лиц в Швейцарию, и каковы варианты их налоговой базы?

    ОБЩАЯ ИНФОРМАЦИЯ

    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

  • IN615 Will Trusts - Ten Basic Facts

    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

  • IN616 New Double Taxation Agreement: Portugal and Angola

    Background

    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.

    Detail

    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

  • IN617 A Report Recognising The Dynamic Growth Of The Malta Financial Services Sector

    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

  • IN618 What Is The Impact Of Brexit Likely To Be For Turkish Nationals Benefiting From The Ankara Agreement?

    The Ankara Agreement enables Turkish nationals to enjoy a number of advantages in terms of emigration to EU countries. 

    Turkish nationals already in the UK, are likely to see little difference once Brexit takes place, with or without a deal, and the Ankara Agreement no longer applies to the UK. There will however be implications for Turkish nationals seeking to move to the UK post Brexit.  … more

  • IN608 Listed Company Services Provided By Dixcart In Guernsey

    Background

    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

  • IN609 Malta Introduces Consolidated New Group Rules - Offering Cash Flow Advantages

    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

  • IN610 Malta's New Patent Box Regime

       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

  • IN611 Portuguse Tax Law - New Provisions To Meet The EU Anti-Tax Avoidance Directive (ATAD)

    Background

    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

  • IN612 Residence/'Golden Visa' Programmes: Cyprus, Malta and Portugal

    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.

    Programme

    Cyprus

    Permanent Residence Permit

    Malta Residence and Visa Programme

    Portugal

    Golden Visa

    Any Jurisdictions … more

  • IN613 Malta: New Consolidated Group Rules And New Patent Box Regime

    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

  • IN614 The EU Anti-Tax Avoidance Directive (ATAD) and Implementation Across Europe

    Measures are increasingly being taken to counteract tax avoidance and EU countries such as Portugal and Malta are fully committed to meeting these obligations, as evidenced by recent tax laws that they have introduced.

    Background

    ATAD was presented as part of the European Commission Anti-tax Avoidance package, at the start of 2016. The objective is to create a ‘level playing field’ across … more

  • IN464 - The Cyprus Investment Programme and the Benefits

    The Cyprus Investment Programme is rapidly becoming one of the EU’s most popular residence schemes.

    Non Cypriot citizens (and their families) can acquire Cyprus Citizenship by investing €2.5 million* in Cyprus.

    *In one specific set of circumstances as detailed below in the financial criteria, the investment required is €2.0 million.

    A non-Cypriot citizen who meets one of the financial … more

  • Dixcart Domiciles Newsletter Second Edition

    Click HERE to read the Dixcart Domiciles Newsletter.

    This edition focuses on the jurisdictions of Cyprus, Greece, Portugal, Switzerland and the UK. Articles include:

    What is unique about the Cyprus Investment Programme?

    What is it like to live in Cyprus? An Interview with Robert Homem, Managing Director of Dixcart Management (Cyprus) Limited.

    Portugal: The €350,000 fund route to Portugal’ … more

  • IN607 Family Office Management: Location, Organisation and Liaison

    Recent Changes

    Recent changes in terms of global tax regulations and increasing international tax transparency are vital to consider when implementing strategies to preserve family wealth and family business ownership structures.

    New global regulations include: Common Reporting Standard (‘CRS’), the US Foreign Accounting Tax Compliance Act (‘FATCA’), and several jurisdictions now operate … more

  • IN606 A Comprehensive Tool Kit to Meet the Requirements of a Substance Based Regime

    History –  The ‘Substance Regime’

    On 1st January 2019 the ”substance-based regime” was introduced into the Crown Dependencies (Guernsey, Jersey and the Isle of Man). 

    This has meant that since January 2019, companies engaging in “relevant activities” have had to demonstrate that they meet specific substance requirements, to avoid sanctions.

    This ‘Order’ is in response to a comprehensive review, … more

  • IN603 (S) El Uso De Fundaciones Educacionales Nevis Para Proteger La Identidad De Los Miembros Jóvenes De Una Familia

    Bienes valiosos

    A menudo, nos preguntan cuáles son nuestros bienes más importantes. Esto suele conducir a un sinnúmero de respuestas, la más común es “nuestros jóvenes”.

    Con frecuencia, muchas familias gastan fortunas en la protección, la educación y la crianza de sus hijos para que se abran su propio camino al mundo. Sin embargo, existen muchos países en los cuales la protección del nombre … more

  • IN603 The Use Of Nevis Educational Foundations To Protect Junior Members Of A Family

    Valuable Assets

    We are often asked, what are our most important assets?  This can lead to a myriad of responses, with the most common being, “our children”. 

    Families often spend fortunes, protecting, educating and nurturing their children, to allow them to make their own way in the world.  Alarmingly, there are a number of countries, where the protection of a family’s name and the identity of … more

  • IN605 Moving To Guernsey: The Benefits And Tax Efficiencies

    Background 

    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. The Bailiwick of Guernsey comprises three separate jurisdictions: Guernsey, Alderney and Sark. Guernsey is the largest and most populated island in the Bailiwick. Guernsey combines many of the reassuring elements of UK culture with the … more

  • IN602 The Cyprus Non-Domicile Regime - An Attractive Tax Regime For Individuals Relocating To Cyprus

    Why Cyprus?

    Cyprus has become an attractive option for companies and individuals. Advantageous tax incentives exist and Cyprus is popular as both a corporate and residential location, offering a sound infrastructure, and also enviable weather. 

    Benefits Enjoyed by Tax Residents of Cyprus who are not Domiciled in Cyprus

    As a result of pre-existing tax legislation and the exemption from Cyprus’ … more

  • IN604 UK Tax Considerations For Short Term Business Visitors To The UK And For Non-UK Resident Directors Of UK Companies

    Background

    When individuals not resident in the UK are short term business visitors to the UK and/or are directors of UK companies, the individual’s UK tax position needs to be considered carefully. UK tax may be due, but there are a number of options that might reduce or negate the UK tax payable.

    Short Term Business Visitors

    Short-term business visitors are individuals who are not resident … more

  • IN601 The EU Settlement Scheme (EUSS) - What UK Businesses and Employers Need to Know

    On 30 March 2019, the EUSS was fully implemented under UK immigration rules, as a post-Brexit system. This allows EEA and Swiss citizens, and their family members, to continue to live and work in the UK – EEA is short for the European Economic Area comprising the EU, Iceland, Liechtenstein, and Norway.

    Successful EUSS applicants will have their immigration status in the UK protected, regardless … more

  • IN599 Taxation Of UK Commercial Real Estate And Foreign Ownership

    Property in the UK can be owned by a company or by an individual and the method of ownership and the status of the company or individual involved will affect the tax treatment.

    Tax on Rental Profit

    Where an investment is made in UK commercial property in the name of a non-UK resident company and the company does not carry on a trade in the UK, basic rate income tax (currently 20%), is … more

  • IN598 Forthcoming Changes In Tax Status For Non-UK Resident Companies With Income From UK Property

    Changes Being Introduced in April 2020

    From April 2020, non-UK tax resident companies with income from UK property will no longer be charged UK income tax and will instead be subject to the UK’s corporation tax regime.

    When the changes come into force, these companies will need to calculate their profits in accordance with corporation tax principles, which may represent a significant change … more

  • IN597 Maltese Foundations And Potential Benefits When Re-Domiciling A Foreign Foundation To Malta

    Malta private foundations have been used for asset protection and succession planning for several years. Amendments, at the end of 2018 to the ‘Voluntary Organisations Act’ enable foreign organisations, including private foundations, to be redomiciled to Malta.

    Malta Foundations

    Malta foundations are governed by the ‘Civil Act’ and the ‘Voluntary Organisations Act’ and are constituted as a … more

  • IN596 Features Which Make Isle Of Man Foundations Attractive Asset Protection Vehicles

    FEATURES WHICH MAKE ISLE OF MAN FOUNDATIONS ATTRACTIVE ASSET PROTECTION VEHICLES

    Background

    Common law countries have traditionally used trusts while civil law countries have historically used foundations. Many individuals in civil law countries remain more comfortable with the concept of a foundation as it is a vehicle that they are familiar with and it is often viewed as being more … more

  • IN591 Tax Reform Package For Swiss Companies Is Approved

    Historically, Swiss companies have enjoyed a zero tax regime for capital gains and dividend income.

    Trading companies, however,  have always attracted a local canton (region) tax rate. The new tax changes focus on trading profits. 

    New Corporate Tax Rate - Geneva

    As from January 2020, the corporate tax rate (combined federal and cantonal tax) for all companies in Geneva, will be 13.99%.

    The … more

  • IN600 The Advantages Of Using A Swiss Company To Hold Investments Owned By Turkish Residents Or Companies

                                                                                                         

    Introduction

    Turkish shareholders with foreign portfolio investments, should consider owning these investments through a Swiss company, in particular if these investments are held in Switzerland.

    What are the Key Advantages?

    a) Profit, taxed in Switzerland, will be at a rate of between 10.1% … more

  • IN595 The Future of Nevis As An International Financial Centre

    Nevis is a modern, forward-thinking financial centre located within the Eastern Caribbean.  It has a unique history of legislative and fiscal independence and is at the forefront in providing  practical solutions to an increasingly mobile and international client base.

    Nevis has developed a number of attractive options, over the years, to meet corporate and individual needs, allowing clients to … more

  • IN595 (S) San Cristóbal y Nieves Como Centro Financiero

    San Cristóbal y Nieves es un centro financiero moderno y con visión de futuro situado en el este del Caribe. Tiene una historia singular de independencia legislativa y fiscal y está a la vanguardia de proporcionar soluciones prácticas a una base de clientes internacionales cada vez más móvil.

    San Cristóbal y Nieves ha desarrollado un número de opciones atractivas en los últimos años para hacer … more

  • IN594 UK Stamp Duty Payment Due Within 14 Days Of Completion

    When buying a property in the UK over a certain price, stamp duty is payable.

    Since 1st March 2019 UK Stamp Duty (SDLT) must be paid to HMRC within 14 days of completion, or the purchaser may be subject to a penalty.

    There is a fixed penalty of £100 for returns filed up to three months late, increasing to £200 for returns which are filed more than three months late.

    What is UK Stamp Duty? … more

  • IN593 Malta FinTech Version 2021 And Developments In The Approach Towards Artificial Intelligence

    Background

    Malta has established itself as an innovative island.

    Practical, workable regulations have been successfully introduced for gaming and blockchain/crypto businesses and Malta is now preparing for the next generation of development within the financial service sector. New initiatives include Malta ‘FinTech Vision 2021’ and the ‘Artificial Intelligence Project’.

    FinTech Vision 2021 … more

  • IN592 Obtaining A Portuguese Golden Visa By Investing In A Portuguese Venture Capital Fund

    Why a Portuguese Golden Visa?

    The Portuguese Golden Visa scheme enables non-EU individuals to obtain the right to reside in Portugal for up to five years. This allows them and their family to travel freely to and from the majority of European countries.

    A Portuguese Golden Visa can lead to permanent residence and/or Portuguese citizenship and the right to a EU passport at the end of the fifth … more

  • IN589 The Definition Of And Approach To The Taxation Of Crypto-Currencies In Malta

    Background

    Malta is one of the countries most advanced in terms of legislation regarding crypto-currencies and has developed a pragmatic approach in relation to the taxation of this asset type.

    The Malta Commissioner for Revenue has issued three guidelines regarding the tax treatment of distributed ledger technology (‘DLT’) assets. Each of the guidelines relates to a different tax: income tax, … more

  • IN588 Increasing Demand For Malta Freeport Services And Regulation Of Malta Free Zones To Promote Further Expansion

    Malta’s Strategic Location in the Mediterranean

    Malta is a country located in a strategic position in the middle of the Mediterranean. Due to its location Malta has been a major centre for maritime operations for generations. This historical heritage and robust transport links, via air and sea, help to make Malta an ideal hub to establish an international company.

    Malta’s strategic geographical … more

  • IN586 Why Use A Family Investment Company?

    What is a Family Investment Company and Why Have One?

    As anti-avoidance legislation aimed at trusts, is increasing, people are looking for alternatives to protect a family’s fortune.  Whilst many people are happy to pass ownership to others they often wish to retain control. 

    Family investment companies (“FICs”) are being used increasingly by wealthy families to protect their family fortunes. … more

  • IN585 Effective Family Wealth Planning

    Dixcart Expertise in Relation to Wealth Structures

    The Dixcart Group has over forty-five years’ experience in assisting clients to run and manage Family Offices.

    We are very familiar with the issues facing families in this ever-changing international world and have extensive experience in providing trustee services in a number of jurisdictions.

    We take time to establish and develop close … more

  • IN584 Annual Dixcart Seminar 2019 - The Future Of International Succession Planning

    Seminar Topic

    On Thursday 28 March 2019, Dixcart hosted its Annual Tax and Trust Seminar; this year titled: ‘The Future of International Succession Planning’.

    Sean Dowden, Managing Director of Dixcart Portugal, chaired the Seminar and began by introducing the Dixcart Group and covering some of the key reasons why succession planning is such a necessity.

    The transfer of wealth to the next … more

  • IN583 An Opportunity For Organisations To Legally Produce Medicinal Cannabis In Malta

    Background

    A new legislative initiative in Malta means that it is now possible to grow and process cannabis (marijuana) in Malta, as long as it is for medical use. This presents an opportunity for entrepreneurs and investors.

    Due to its geographical position Malta is also conveniently placed, as a potential distribution hub for medical cannabis.

    Entities need to apply to produce and/or process … more

  • IN582 How Can Individuals Move To Switzerland And What Will Their Basis Of Taxation Be?

    BACKGROUND

    Many foreigners move to Switzerland for its high life quality, outdoor Swiss lifestyle, excellent working conditions and business opportunities.

    A central location within Europe with a high standard of living, as well as connections to over 200 international locations via regular international flights, also make Switzerland an attractive location.

    Many of the world’s largest … more

  • IN581 'SIGI' - A New Type Of Portuguese Real Estate Company And Its Benefits

    Background

    Recent interest from the international financial and investment community in  Portuguese real estate has motivated the Portuguese Government to introduce a new investment vehicle, exclusively dedicated to real estate investment.

    Introduced in February 2019, the ‘Sociedades de Investmento e Gestao Imobiliaria’, (‘SIGI') introduces a number of features generally associated with Real … more

  • IN580 Reforms to UK Investor Visa Category and New Entrepreneur Visa Routes

    On 7 March 2019, the UK Home Secretary laid Statement of Changes to the UK Immigration Rules before Parliament, with these changes being introduced from 29 March 2019.

    The changes primarily concern the closure of the Tier 1 (Graduate Entrepreneur) and Tier 1 (Entrepreneur) categories to new applicants, and these are replaced by the Start-up, and Innovator visa routes. The Tier 1 (Investor) … more

  • IN579 Guidelines: Determination of the Place of Supply - Hiring of Pleasure Boats in Malta

    The Malta Commissioner for Revenue has just published the guidelines that are to be used to determine the place of supply for the hiring of pleasure boats. These will be applicable, retrospectively, for all leases commencing on or after 1 November 2018.

    These new guidelines are based on the fundamental VAT principle of ‘use and enjoyment’ and provide the mechanism to determine the amount of VAT … more

  • IN578 UK Immigration - What Might Be Expected in 2019

    UK laws generally change at a fast pace and this is particularly the case when it comes to immigration.

    Brexit

    Brexit is very much a live issue and is still scheduled to take place on 29 March 2019. The terms of the UK’s departure from the EU are unclear but a few possibilities, in relation to immigration, are outlined below:

    the current draft Withdrawal Agreement is ratified by the UK and … more