IN642 Offshore Planning for Ultra High Net Worth Individuals Using Corporate Family Investment Structures
Family investment companies continue to prove popular as an alternative to trusts in wealth, estate and succession planning.
What is a Family Investment Company?
A family investment company is a company used by a family in their wealth, estate or succession planning which can act as an alternative to a trust. Their use has grown significantly in recent years, particularly in instances where it … more
Redomiciliation of a Shipping Company to Malta
Malta has established itself as a robust and safe maritime jurisdiction and has the largest European maritime flag registry.
It is possible to redomicile a shipping company from another jurisdiction to Malta, without liquidating the company in the country that it is being redomiciled from (Legal Notice 31, 2020).
A Summary of the Attractive Tax … more
It is March 2020 and two people are sitting at the departure gate at Heathrow waiting for their delayed flight to the Bahamas. They start a conversation and talk about why they are flying to this Caribbean island.
Person A, Mrs Exiteer, explains to Person B, that she had lived in the UK for a long time as a resident “non-dom,” but that changes to the tax rules for longer term … more
What is the Good News?
The period of uncertainty regarding the future of Nevis companies is coming to an end and the future for Nevis looks more positive.
In summary, companies that can demonstrate they are non-resident, that is companies with central management and control outside Nevis and no permanent establishment in Nevis, may continue to enjoy a tax neutral environment.
In 201 … more
What is Changing?
India is tightening its residency provisions specifically to push ‘stateless’ persons (Indian nationals), who are not liable to tax in any other country, within the Indian tax net.
In addition, in order to become non-resident in India you will have to stay outside of India for at least 240 days per tax year and as detailed above, Indian citizens will also need to be liable to … more
Spring 2020, and we are experiencing an unprecedented period in terms of threat to health and economic stability.
Lower key disruption took place in April 2010, due to the ash caused by a volcanic eruption in Iceland and the subsequent cancellation of a large number of flights.
At this current time, there may be a number of other, less serious, but important unforeseen consequences.
Tax … 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.
The ‘Ankara Agreement’, as it is commonly referred to, was signed in 1963 between the Republic of Turkey and the European Economic Community (EEC). The Agreement was designed to encourage Turkey to become a Member State of the EEC by promoting economic relations. … more
Although the UK is no longer a member of the EU, a transition period is currently in place until at least 31 December 2020. During this period, most EU laws including EU free movement rules, continue to apply in the UK.
It remains to be seen how negotiations between the UK and the EU will affect the future relationship; however, the UK remains an attractive destination for … more
IN550 Visas Available to Non European Economic Area (EEA) Individuals Allowing Them to Work in the UK
This article summarises some of the UK immigration options available to individuals to conduct business and/or work in the UK. For information on the Tier 1 (Investor), the former Tier 1 (Entrepreneur), Start-up, and Innovator visa categories please see: Information Note 580
Short-Term Business Trips
It is possible to visit the UK and conduct business of a limited nature for up to … more
Individuals granted a Tier 1 (Entrepreneur) visa or Tier 1 (Investor) visa under the existing rules before/on 28 March 2019, as detailed below, are generally unaffected by 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 … more
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
On 30 March 2019, the EUSS was fully implemented under UK domestic 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.
Although the UK is no longer a member of the EU, a transition period is currently in … more
The Dixcart Group has more than 45 years of experience in assisting wealthy individuals and their families in matters of succession, estate planning and in the efficient administration of their affairs.
The Dixcart Group can assist with the formation and administration of trusts, foundations, private and managed trust structures and other family office services and is able to offer these … more
Malta launched a Malta and Africa strategy for partnership 2020 – 2025, for public consultation, at the start of 2020. This strategic approach to Africa reflects the growing importance of this continent in relation to trade, development and diplomatic objectives.
The African Continent in the Modern World
The Maltese Government views Africa as a vital strategic partner for the future. It is an … more
A key Double Tax Treaty (DTT) came into force between Cyprus and the UK in 2019. In addition, two new Cyprus DTTs came into force early 2020, with Ukraine and Kazakhstan.
This Article highlights the most important features of each treaty. If you would like further detail and information regarding any relevant exceptions please contact the Dixcart office in Cyprus: firstname.lastname@example.org. … more
UK tax resident, non-domiciled, individuals who are claiming the remittance basis of taxation, do not pay UK 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 planned for and claimed. For more information regarding formally claiming the remittance basis, please see Information Note 498. … more
In the last decade, people have become increasingly concerned regarding safety and personal/economic growth in relation to themselves and their families. This has helped motivate the emergence of the modern phenomenon: the ‘World Citizen’. Families are increasingly making the brave decision to either gain new nationality or obtain additional nationality, in order to enhance their lives and … more
Robert Homem, the Managing Director of Dixcart Cyprus, is delighted to announce that the Dixcart office in Cyprus moved to its new premises in Limassol, during the first week of December 2019.
Substantial red-tape and two sets of Planning Permissions had to be navigated, as well as a number of complications in relation to the electricity supply. A few grey hairs were gained.
The Dixcart … more
The UK continues to be a favoured place for technology start-up companies, with 2019 investment growth, outpacing that of both China and the US.
According to the Government backed ‘Tech Nation Dealroom’, British technology start-ups raised $13.2 billion in 2019, an increase of 44% compared to 2018.
Eric Schmidt, who was the Chief Executive Chairman of Google for six years to 2017, stated; “ … more
With Brexit due to take place on 31 January 2020, UK immigration rules for EU citizens are likely to face further change. At the same time, the UK recognises the need to continue to attract talent from overseas and a number of measures introduced during 2019 indicate the direction that the UK is likely to be taking regarding immigration in 2020.
Since 28 January 2019, UK employers have … more
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
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
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
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
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
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
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
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
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
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
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