• 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

  • IN587 Key Changes To The Cyprus Citizenship By Investment Programme

    In February 2019 the Cyprus Council of Ministers approved revisions to the Cyprus Citizenship by Investment Programme. These changes include the addition of contributions to research and development within Cyprus and to fund affordable housing on the Island.

    Changes with Immediate Effect

    Three changes to the programme came into effect immediately:

    The minimum amount of time for which the … 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 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 alternative residence.

    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

  • IN577 Luxury Assets such as Aircraft and Yachts and Preparation for Brexit

    Aircraft and Yacht Registration and VAT Considerations

    The recent political upheaval with the United Kingdom leaving the European Union (Brexit) at the end of March 2019, has left many yacht and aviation owners with a potentially unquantified problem (both financially and legally).

    The VAT and registration (aircraft and/or yacht) arrangements in place before Brexit, may need consideration and … more

  • IN576 Key Measures Relating to EU ATAD Now Implemented in Malta

    As a member of the EU, Malta has implemented the EU Anti-Tax Avoidance Directive (ATAD) and has incorporated it into domestic legislation.

    Malta incorporated the ATAD measures into its domestic legislation at the beginning of December 2018 through implementation of Legal Notice 411, which includes the following:

    an interest limitation rule;

    general anti-abuse rules (GAAR);

    controlled … more

  • IN575 Increased Cash Rebates Film Production in Malta

    Background

    The Maltese Government is committed to promoting the film production sector and cash rebates can be claimed, as a financial incentive, to the growing Audio-visual Industry in Malta.

    What Rebates are Available?

    Starting from January 2019, qualifying companies can receive a maximum 40% cash rebate for film production in Malta.

    The cash rebates are rebates on the expenses in Malta, … more

  • IN574 Guernsey - Why Is It a Centre of Fintech Excellence?

    Background

    The current digital age brings with it new challenges and opportunities for the finance sector. As far back as 20th July 2015 the States of Guernsey released their report ‘A strategic vision for FinTech’ drafted by PwC and contributed to by more than 70 representatives of local industry and the FinTech sector including Dixcart Trust Corporation Limited.

    FinTech, as defined by the … more

  • IN572 Individual Taxation In The UK

    Liability to UK tax is broadly determined by the application of the concepts of "domicile" and "residence".

    Domicile

    UK law relating to domicile is complex and differs from the laws of most other countries. Domicile is distinct from the concepts of nationality or residence. In essence, you are domiciled in the country where you consider you belong and where your real and permanent home is. … more

  • IN571 Routes To UK Residence And Citizenship

    Individuals granted a Tier 1 (Entrepreneur) visa or Tier 1 (Investor) visa under the existing rules before/on 28 March 2019 are generally unaffected by the new rules effective from 29 March 2019. For more information, please refer to Dixcart Article: IN580 Reforms to UK Investor Visa Category and New Entrepreneur Visa Routes

    Who Can Move to the UK?

    EEA nationals and their family members have … more

  • IN570 Armed Guards To Be Allowed On Board Portuguese Flagged Ships - Where Piracy Is Prevalent

    New Law

    On 10 January 2019, the Portuguese Council of Ministers approved a law to allow armed guards to sail on Portuguese flagged vessels.

    This measure is long-awaited by the International Shipping Registry of Madeira (MAR) and by ship owners registered within it. The increase in financial loss due to hijackings and ransom demands, and the risk to human lives, as a result of hostage taking has … more

  • IN569 Using Switzerland For Asset Protection In An Increasingly Challenging World

    Background

    Switzerland is an incredibly attractive jurisdiction for international companies and high net worth individuals, seeking stability (political and economic).

    Taking into account the many factors that influence the choice of jurisdiction, the case for Switzerland is a strong one.

    Reasons Why Switzerland is a Favoured Location

    Political, financial, social and economic stability … more

  • IN568 Portuguese Golden Visa - Investment Route And The Non-Habitual Residents Regime

    Background

    Portugal is being re-discovered as a destination to relocate to, with iconic cities such as Lisbon and Porto, and stunning coastal areas, for example, the Algarve. It also offers very easy access to the rest of Europe.

    Portugal is increasingly recognised as an international hub with 71 Double Taxation Agreements and 49 Investment Protection Treaties.

    The Golden Visa

    The Portuguese … more

  • IN567 Moving To Italy - The Resident Non-Domiciled Tax Regime

    Background

    During 2017 the Italian Government introduced a new tax regime: The Resident Non-Domiciled Tax Regime (also known as the "Flat Tax Regime"), with the aim of attracting high net worth individuals who want to relocate to Italy. 

    The new legislation introduced a key change to the general principle of worldwide taxation for Italian tax residents. According to these provisions an … more

  • IN566 Significant Tax Advantages Available To Individuals Moving To Guernsey

    Background

    Guernsey is one of the Channel Islands and is situated in the English Channel, close to the French coast of Normandy.

    Whilst retaining very close links to Britain, Guernsey is independent from the UK and has its own democratically elected parliament which controls the island's laws, budget and levels of taxation.

    What Tax Advantages are Available to Individuals Moving to Guernsey? … more

  • IN518 - Why the Madeira International Shipping Register (MAR) is so Attractive and the Advantages of Registering a Vessel in Madeira

    Background

    The objective of the Madeira International Shipping Register (MAR) is to offer a credible alternative to other international registers. The high quality and safety standards of a conventional register have been maintained within an attractive tax environment designed to encourage inward investment to the island of Madeira. Vessels registered with MAR carry the Portuguese flag and are … more

  • IN450 - A Move of Residence

    Please note that as a general principle EEA citizens are free to move to other EEA countries. Switzerland is in the Schengen Area and as such EEA citizens can move there and vice versa. The residence schemes detailed (excluding St Kitts & Nevis) are therefore applicable to non-EEA individuals for each of the countries featured.

    Please note, however, that where freedom of movement is not the … more

  • IN563 The Option of A Second Passport - St Kitts & Nevis Citizenship by Investment

    Individuals and families are becoming increasingly mobile and the ability to hold a second passport is becoming more relevant. The Caribbean is an attractive destination for a number of reasons, including the relaxing lifestyle, beautiful scenery and the climate. There are also opportunities to hold a second passport, even if the immediate intention is not to relocate to the Caribbean.

    Why do … more

  • IN564 Update: The Proposed Tax Reform Of Swiss Companies

    Background

    Reform of the taxation of Swiss companies has been on the agenda for a considerable length of time. On 28 September 2018, the final draft of the Federal Act on Tax Reform and "AHV" Financing ("TRAF") was approved by the Swiss Parliament.

    AHV is an obligatory payment for every individual over the age of 20 living in Switzerland. It is an insurance for old age and/or for the bereaved. … more

  • IN565 Why Use The Azores (Portugal) For Yacht Importation?

    Background

    The Archipelago of the Azores is composed of nine volcanic islands and is situated in the North Atlantic, about 1,500 kilometres west of Lisbon. These islands are an autonomous region of Portugal.

    What Advantages are Offered by the Azores for Yacht Importation into the EU?

    The standard rate of Portuguese VAT is 23% but the Azores benefits from a reduced VAT rate of 18%.

    In … more

  • IN561 Key Aspects - Economic Substance Requirements For Guernsey

    1 Introduction

    Like other offshore jurisdictions, Guernsey will be implementing new legislation introducing economic substance requirements for companies in Guernsey. This briefing note sets out key aspects of the Guernsey Government proposed legislation,  noting that further, more comprehensive guidance notes, will follow in due course.

    The proposed legislation is relevant to all companies … more

  • IN562 New Substance Requirements For Isle Of Man Companies - Effective 1 January 2019

    The Isle of Man Treasury has published a draft of the proposed Income Tax (Substance Requirements) Order 2018. This draft Order will, once final, and if approved by Tynwald (in December 2018), have effect in respect of accounting periods commencing on or after 1 January 2019.

    This means that from January 2019, companies engaging in “relevant activities” will have to demonstrate that they meet … more

  • IN556 The Brazil And Switzerland Double Tax Treaty: Why Is It So Significant?

    Background

    The Brazilian and Swiss Governments signed a Double Tax Treaty (DTT) on 3 May 2018.

    Switzerland is one of the biggest investors in the Brazilian market and Brazil and Switzerland have already signed an Automatic Exchange of Information Agreement, which came into force on 1 January 2018.

    This new treaty, follows current OECD standards, including Base Erosion and Profit Shifting (BEPS) … more

  • IN557 Use Of A Guernsey Or Isle Of Man Family Investment Company To Hold UK Assets

    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

  • IN558 Guernsey And The Isle Of Man - Implementation Of Substance Requirements

    Background

    The Crown Dependencies (Guernsey, Isle of Man and Jersey) have introduced economic substance requirements, for companies incorporated, or resident for tax purposes, in each of these jurisdictions, effective for accounting periods starting on or after 1st January 2019.

    This legislation has been designed to meet the high level of commitment made by the Crown Dependencies, in November 20 … more

  • IN560 UK 'Representative Of An Overseas Business Visa' Key Advantages And General Requirements

    Background

    As detailed in a number of previous Information Notes, there are several different UK visa options available to non-EEA nationals, to come to the UK to live and work.

    What is a ‘Representative of an Overseas Business Visa’?

    The “Sole Rep Visa” as it is informally known, is a route designed for senior employees who are non-EEA nationals, enabling them to move to the UK and establish … more