• IN293 - UK Controlled Foreign Companies Rules - And Certain Exemptions That Can Reduce Or Remove The Obligation To Pay UK Tax

    The UK updated its foreign company (“CFC”) rules on 1 January 2013. A number of exemptions apply that can reduce or remove the obligation to pay UK tax.

    Background

    A CFC is a non-UK resident company controlled by persons in the UK.  Typically a CFC is a foreign subsidiary of a UK group, although corporate control is not required for a company to be a CFC. 

    The rules, which are essentially anti- … more

  • IN483 - Access To Complementary Services From Nevis for Professional Firms In Other Jurisdictions

    St Kitts & Nevis offers well-regulated and effective solutions for businesses around the world. It is an international financial centre with innovative corporate and wealth management solutions available to clients. 

    A number of jurisdictions are experiencing increased pressure from the wider international commercial community and/or measures taken by their own Governments. Nevis may be able to … more

  • IN482 - Benefits Offered By Nevis And The Use Of A Managed Trust Company

    Nevis offers a number of wealth planning opportunities which can provide certainty, flexibility and privacy to families who are planning for the future. 

    Numerous tax benefits are available to international companies, limited partnerships and trusts located in Nevis. These include NO income tax, NO social security tax, NO capital gains tax, NO wealth tax, and NO death duty or inheritance tax. … more

  • IN481 - Why Consider Using A Nevis International Business Company For Wealth Planning And Holding International Investments?

    Nevis is a leading international Caribbean financial centre, with a good reputation and excellent compliance standards, making it well suited to holding international investments for wealthy families.

    It can be a challenge for non-European investors to find an efficient and cost effective manner in which to make international investments. The use of a Nevis International Business Corporation ( … more

  • IN480 - St Kitts & Nevis Citizenship by Investment - A Second Passport That Can Assist With Mobility Around the World

    A Second Passport - The Caribbean Solution for Alternative Travel Documents 

    In today’s ever changing world, freedom and ease of travel are becoming ever more important. Residents of many countries suffer from a lack of mobility, which most western countries take for granted.

    Increasingly, wealthy non-EU individuals are applying for residence, and in some instances, citizenship in European … more

  • IN475 - Moving Location - A Critical Time to Plan for Succession

    Wealth – a Responsibility 

    The transfer of wealth to the next generation is a critical issue. The ability and understanding of the next generation as to how to deal with the organisation and management of the wealth being passed to them is also a vital consideration.

     A family’s financial wellbeing can be lost or reduced in disputes over control and management of the wealth. Unfortunately the … more

  • IN477 - Trusts Accounts Broken? – We Can Help Fix Them

    Introduction

    Trustees have never had more reason to ensure that their internal systems and controls are fit for purpose.

    The main drivers behind the need to assess these are:

    Increasing global scrutiny of wealth management structures by tax authorities

    Global transparency and exchange of information

    The establishment of beneficial ownership registers

    The pressure on and from regulators to … more

  • IN479 - Guernsey Register of Beneficial Ownership – A Unique Approach

    Background

    In February 2017, Guernsey’s Government approved the establishment of a register of beneficial ownership information.

    In implementing this initiative, Guernsey, along with a large number of other jurisdictions, is maintaining its commitment to meet international standards on tax transparency and is adopting the recommendations of the Financial Action Task Force.

    This new Register … more

  • IN478 - Portugal – An Increasingly Attractive Location for Entrepreneurs

    Background

    Historically, Portugal’s ‘brightest and best’ have looked for opportunities outside of Portugal. This was not necessarily because they wanted to, but because Portugal was more focused on keeping its head above water and on finding ways to leave the Economic Adjustment Programme agreed with the European Commission for the period 2010-2014 (the bailout programme).

    Whereas in the past … more

  • IN476 - Trust / Foundation Hybrid Structure – An Asset Protection Structure for Internationally Mobile Individuals

    Background

    Asset protection and wealth preservation continues to be a primary focus for high net worth individuals. 

    However, the ever increasing international mobility of individuals and their families means that the traditional Common Law jurisdiction solution of a Trust, or Civil Law jurisdiction solution of a Foundation may not, in isolation, prove to be optimum solutions for an individual’ … more

  • IN431 - The Isle of Man Alternative Banking Regime - Opportunities for Corporate Organisations and Representative Offices

    The Alternative Banking Regime (ABR) in the Isle of Man can provide a number of opportunities for organisations. Discussions with clients and professional colleagues regarding the new regime have identified a number of potential applications and benefits of the ABR.

    Legislative Structure

    The ABR was introduced on 1 August 2016 and expands the existing Class 1 (deposit taking) banking licence to … more

  • IN474 - Providing Professional Firms in the BVI with Access to Complementary Services from Nevis

    Nevis and the British Virgin Islands (BVI) are countries within the Caribbean that offer well-regulated and effective solutions for businesses around the world. They are international financial centres offering clients innovative corporate and wealth management solutions.  

    A number of similar corporate services are available in the two jurisdictions but, due to recent Government rule changes in … more

  • IN473 - The Organisation of a Fund in Malta - The Benefits

    Dixcart is licensed to provide fund administration services in Malta and in the Isle of Man. 

    We provide a comprehensive range of services in Malta including accounting and shareholder reporting, corporate secretarial services, fund administration, shareholder services and valuations.

    The Benefits of Establishing a Fund in Malta

    A key benefit in terms of using the jurisdiction of Malta for the … more

  • IN472 - Yacht Registration in Malta: The Commercial and Leasing Opportunities

    During the past decade Malta has consolidated its status as an international centre of maritime excellence. Currently Malta has the largest shipping register in Europe and the sixth largest in the world. 

    Malta has also become a world leader in terms of commercial yacht registration.

    Yacht Registration in Malta

    Commercial and pleasure yachts can be provisionally registered under the Malta flag … more

  • IN471 - Malta - Attractive Residence Programmes and Tax Benefits for Expatriates

    Malta offers five residence programmes to meet different individual circumstances. Some are appropriate for non-EU individuals while others provide an incentive for EU residents to move to Malta.

    The five residence programmes and the tax benefits they can provide for individuals, where relevant, are detailed below.

    INDIVIDUAL INVESTOR PROGRAMME

    The Individual Investor Programme (IIP) … more

  • IN470 - Malta Holding Companies - Why Are They So Attractive?

    Beneficial Characteristics for the Location of an International Holding Company

    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. 

    Ideally the holding company should be resident in a jurisdiction which: 

    Has a good double tax treaty network, thereby minimising … more

  • IN469 - The Annual Dixcart Seminar - March 2017: Risk Mitigation for Family Offices and Corporates

    As many of you know, each year Dixcart hosts a seminar. This year the topic was risk mitigation for family offices and corporates and was held at the Institute of Chartered Accountants in England and Wales (ICAEW) in London.

    Risk is an increasingly important factor to mitigate for any business and for this particular seminar Dixcart chose to highlight the areas of geographic risk, family risk, … more

  • IN468 - Worldwide Disclosure, UK Tax Liabilities and What You Should Do

    The Worldwide Disclosure Facility (WDF) runs from 5 September 2016 to 30 September 2018. It is designed to enable taxpayers to disclose a UK tax liability which relates wholly or partly to an offshore issue.

    All other offshore disclosure facilities have now closed and this is the final opportunity for UK taxpayers to come forward before the Common Reporting Standard (“CRS”)  information exchange … more

  • IN467 - Another Reason to Choose Cyprus - The Cyprus Non-Domicile Regime

    Cyprus is an attractive option for the relocation of both companies and individuals.

    This island offers a warm climate, good infrastructure, convenient geographic location, membership of the EU, tax advantages for companies and incentives for individuals through the Cyprus non-dom regime.

    Background

    The Cyprus House of Representatives approved new tax laws on 9 July 2015, which took effect on 1 … more

  • SA3 - Dixcart Group: More than 45 Years of Providing Professional Assistance to Internationally Mobile South African Families

    South African families are currently experiencing a number of challenges. Increasingly, South African families are looking at international wealth protection strategies, business relocation options, and residency and citizenship solutions in the UK, Europe and elsewhere. Safety, security and currency volatility are big drivers, but political, economic and educational issues play their part too.  … more

  • IN466 - Dixcart Business Centres: Serviced Offices Where and Why?

    Dixcart Business Centres offer extensive serviced office capacity and are ideal for companies establishing themselves in a new location. Dixcart Business Centres are located in Guernsey, the Isle of Man, Madeira (Portugal), Malta and the UK.

    Business Centres can offer a productive work environment and a cost effective option for organisations with international interests wishing to operate from … more

  • IN465 - 2-REG Channel Islands Commercial Aircraft Registry: Case History Highlighting the Advantages of Temporary Registration

    Established in December 2013, “2-REG”, the Channel Islands Aircraft Registry, is the aircraft registry of the States of Guernsey. The nationality mark is ‘2’ followed by four letters, allowing for attractive registration marks.

    There have been 94 registrations to date of lessor owned aircraft, corporate aircraft, including a Boeing 787-8 Dreamliner, and locally owned aircraft. The registry is … more

  • IN464 - Fast Track Cyprus Citizenship by Investment and the Benefits it Offers

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

    A fast track procedure exists for non Cypriot citizens (and their families) to acquire Cyprus Citizenship by investing €2.5 million* in Cyprus.*€2.0 million in one set of circumstances as detailed in the financial criteria.

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

  • IN463 - Isle of Man Financial Assistance Scheme - Enabling Entrepreneurs to Innovate on the Island

    The Isle of Man has long been known as a welcoming home to entrepreneurs and innovators. It has achieved this over the years by playing to its strengths, having strong communication with the private sector, supporting new ideas and new ways of thinking, changing legislation quickly, and because it has wanted to lead not follow. E-business, for example, has found a home in the Isle of Man, with … more

  • INSAA - Why Companies and Individuals are Relocating to the UK and a UK Entrepreneur Visa Case Study

    During 2016 and also this year, an increasing number of Dixcart contacts are expressing interest in moving to the UK, either for themselves personally or for their clients.  They are not only attracted to the UK due to its rich culture and the British "way of life," it is also because of the tax advantages available for both companies and individuals.

    London was rated top city in the world in 201 … more

  • IN462 - An Effective Guide: How to Reinstate a Cyprus Company

    At the end of 2016 thousands of Cyprus companies were struck off – as the Cypriot Government recognised that many had been inactive for a number of years.

    This Information Note considers why these companies were struck off and explains the relatively straightforward process for a company to be reinstated.

    Why were Cyprus Companies Struck Off?

    There are two reasons why the Cyprus Registrar of … more

  • IN461 - The Advantages and Relevant Procedures to Migrate a Company or Foundation to Guernsey

    Why is Guernsey an Attractive Jurisdiction for Companies?

    There are a number of reasons why an individual may wish to migrate a company or foundation from its current jurisdiction of registration to the Bailiwick of Guernsey.

    Guernsey is a well-regulated and internationally respected international jurisdiction.  It is also a politically stable jurisdiction with its own autonomous government but … more

  • IN460 - What Financial Assistance is Available Through the Isle of Man Enterprise Development Scheme?

    Entrepreneur Government Funding

    The Isle of Man has long been known as the home of entrepreneurs and innovators. This has been achieved over the years by playing to its strengths; strong communication with the private sector, supporting new ideas and ways of thinking, changing legislation quickly, and because it has wanted to lead not follow.

    E-business has found a home in the Isle of Man with … more

  • IN459 - Relocating a Company to the UK? Why Consider the Dixcart Business Centre

    Individuals wishing to establish a company in the UK may, for a variety of reasons, consider the use of a Business Centre offering serviced office capacity, which will provide substance. Business Centres can offer a productive work environment and a cost effective option for organisations with international interests wishing to operate from a particular location.

    A company establishing itself in … more

  • IN458 - Reduced Costs for the St Kitts & Nevis Citizenship by Investment Programme and Ability to Pass Citizenship to Future Generations

    From the 1st of February 2017 a number of changes were made to the criteria required for a donation to the Sugar Industry Diversification Foundation (SIDF) to gain St Kitts & Nevis Economic Citizenship. These changes make this Citizenship option an even more attractive and cost effective proposition.

    For additional information regarding St Kitts & Nevis Citizenship, please see: IN 308 – St Kitts … more

  • IN457 - Thinking of Flagging or Reflagging a Vessel? - Malta Could be the Answer

    A lot of uncertainty has been generated within Europe following on from the Brexit vote, and certain other countries who are beginning to reassess their position within the EU. This is having an impact on the marine industry, with a number of vessel owners seeking to reflag ships and yachts.

    The choice of flag registration is an important decision and a jurisdiction must be selected that … more

  • IN456 - Reasons Why the Double Tax Agreement Between Cyprus and South Africa is so Attractive

    South Africa is one of the most sophisticated and promising emerging markets globally.

    The potential offered by the South African economy is evident in its 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 resources, have made it a popular country … more

  • IN455 - Image Rights Registration and the Future Benefits This Can Offer

    Guernsey’s innovative legislation on Image Rights (IR) became law in November 2012 and it remains the only jurisdiction in the world to date where an individual, group or legal entity can register their Image Rights on a public register. 

    Registrations have been steady since that date, with currently 64 IR registrations for individuals and entities from a broad range of human activity, including … more

  • IN454 - Cross-Border Mergers in the EEA: Potential Advantages and the Need to Act Soon if a UK Company is Involved

    With increasing political uncertainty across the world, particularly at the current time in the EU, a cross-border merger can be used as a way to secure business from one country in the European Economic Area (EEA) to another country in the EEA.

    The Cross-border Merger Option Available to EEA Countries  

    For companies resident in EEA states, including the UK, the option of a ‘true’ merger … more

  • IN423(SP) - Servicios De Family Office

    Introducción

    Con la creciente movilidad de los empresarios y personas ricas por todo el mundo, por razones comerciales o personales, existe una mayor necesidad de proveer una base fuera del país de origen o de residencia de las familias de alto patrimonio para coordinar el desarrollo de sus intereses comerciales.

    Una base de impuestos neutral

    Una base suele establecerse en una jurisdicción de … more

  • IN453 - The Use of a Swiss Trustee: How and Why?

    Trusts originated in England in the 12th century and developed across many Common Law jurisdictions. Trusts are now also used by many Civil Law jurisdictions.

    Dixcart in Switzerland and Trust Services

    The Dixcart office in Switzerland is a member of the Swiss Association of Trust Companies (SATC) and is registered with the Association Romande des Intermediaires Financiers in Switzerland (ARIF). … more

  • IN452 - The Benefits of a Swiss Investment Holding Company

    Why are Swiss Holding Companies so Popular?

    There are many reasons why Switzerland is a favoured location for international business. These include:

    Political, financial, social and economic stability.

    A favourable fiscal environment.

    Geneva and Zug are major centres for commodity trading.

    Excellent business support structures and a wide variety of professionals including: lawyers, bankers, … more

  • IN451 - Why are Swiss Intellectual Property Holding Companies so Popular?

    Switzerland is an attractive location for Intellectual Property (IP) companies. It combines a proactive business and tax approach with a stable political and economic environment.

    Holding and administering IP rights in one jurisdiction under one central IP company considerably simplifies the management of group IP rights and enables stronger control.

    Switzerland: A Formidable Intellectual … more

  • IN450 - A Move of Residence

    Please note that as a general principle EU citizens are free to move to other EU countries. Switzerland is in the Schengen Area and as such EU citizens can move there and vice versa. Unless specified, the residence schemes are therefore applicable to non-EU individuals for the countries featured. St Kitts & Nevis is not in the EU and therefore their scheme applies to EU and non-EU individuals.  … more

  • IN449 - Guernsey and the Isle of Man: Convenient Choices to Reset the Clock for UK Non-Domiciles

    The UK non-domiciles regime remains a relatively attractive option with UK non-domiciliaries (“non-doms”) continuing to have the opportunity to enjoy significant tax advantages for a period of up to 15 years.

    Changes to UK Non-Dom Legislation

    Major reforms regarding how non-UK domiciliaries are taxed were however introduced in April 2017.

    As detailed in the Dixcart note: UK Tax Residence - … more

  • IN448 - What Does Malta Offer as a Jurisdiction for Aviation?

    Malta’s reputation, within the EU, as an efficient and relevant jurisdiction for aircraft registration is growing rapidly. 

    Brexit negotiations could have a significant impact on UK registered aircraft doing business in the EU. Airline operators who receive their operating licences from the UK Civil Aviation Authority may no longer be deemed Community Carriers and may no longer enjoy the right … more

  • IN447 - Cyprus Revised Tax Treaty with India

    Cyprus is rapidly expanding its tax treaty network, as illustrated by new treaties with Bahrain (coming into force January 2017) and Latvia (ratified June 2016).

    In addition, in November 2016, Cyprus and India signed a revised Double Tax Treaty. Comprehensive details of the treaty are yet to be released but a number of key measures have been confirmed.

    Key Provisions of the Treaty

    Once the … more

  • IN446 - United Kingdom and United Arab Emirates Double Taxation Agreement - Potential Action to Consider

    On 12 April 2016 the United Kingdom (UK) and the United Arab Emirates (UAE) signed a Double Tax Agreement (DTA).  This is the first DTA to be signed between these two countries. The agreement is yet to come into force and requires ratification by both countries. 

    The DTA contains provisions regarding the location of corporate residence which may have important implications for a number of … more

  • IN445 - Isle of Man Exempt Schemes: A Flexible Solution for Family Offices and High Net Worth Indivduals

    Isle of Man Exempt Schemes are a flexible and attractive option for Private Client Family Offices and high net worth individuals. The Isle of Man has a long established fund sector and the latest Fund Statistical Data (published by the Isle of Man Financial Services Authority for the quarter ended June 2016) recorded 130 Exempt Schemes registered in the Isle of Man, with a combined net asset … more

  • IN444 - Moving to the UK and the Opportunities Provided by the UK Investment Visa and the UK Entrepreneur Visa

    Why the UK?

    The UK is a very popular destination for many individuals. The legal and education systems are of high quality and there is an excellent choice of property, both residential and commercial. It offers a rich culture, traditions and history and has a distinctive “British way of life”, which many people feel comfortable with.

    The UK has a number of international airports; Heathrow, … more

  • IN443 - The Portuguese Comandita Structure and the Benefits it Offers

    There are four different types of company that can be established in Portugal:

    Private limited liability companies (Sociedade por Quotas, LDA)

    Public limited companies (Sociedade Anónima SA Corporation)

    Limited co-partnership companies (Sociedade em Comandita, SC)

    General partnership companies (Sociedade em Nome Collectivo, SNC)

    The third type of company is based on a structure similar … more

  • IN442 - The Isle of Man: A Safe Harbour

    Over the past three decades the Isle of Man has attracted a wide variety of international businesses and individuals, many of whom are still resident in the Isle of Man and have made it their head office and/or home.

    Moody’s Investor Services Limited has recently (September 2016) released a statement stating that the Isle of Man is ‘more diverse and less volatile’ when compared to other offshore … more

  • IN441 - Online Gaming in Malta - An Interview with Sean Dowden, Managing Director of Dixcart in Malta

    In 2000 the Maltese Government passed legislation permitting online betting centres to operate from the island. Since then Malta has become one of the leading jurisdictions for online gaming with over four hundred licences having been issued, representing approximately 10% of the global online gaming market.

    Sean Dowden, Managing Director of Dixcart Management Malta Limited has extensive … more

  • IN440 - Important Changes to the Cyprus (EU) Citizenship by Investment Programme

    On 13th of September 2016, important changes were made to the programme to obtain Cypriot Citizenship by Investment. This programme enables successful applicants to gain a Cyprus (EU) passport.

    Major Changes to the Programme

    The minimum investment has been reduced from €5 million to €2.5 million*.

    *A minimum investment of only €2 million is acceptable provided that the investment is only … more

  • IN438 - The Benefits of the New Cyprus-Iran Double Tax Treaty

    The Governments of Cyprus and Iran signed and ratified a new double tax treaty in August 2015. Cyprus has a favourable tax system with an extensive network of Double Tax Treaties and this new treaty makes Cyprus an excellent gateway jurisdiction for business and investments into and out of Iran.

    The Cyprus Tax System at a Glance

    Resident companies are generally taxed at 12.5% of their … more