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
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
Last Updated: December 2019
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 … more
Corporate entities are established and managed in a number of countries across the world for a variety of reasons. The location chosen for the incorporation and management of a company is a vital factor and integral aspect of the international, commercial planning process.
Business Centres are becoming an increasingly popular feature within international trading centres. They provide an … more
The 5th EU Anti-Money Laundering Directive
In December 2017, the 5th Anti-Money Laundering Directive, a revision of the 4th Directive, was launched after the Panama Papers leaked the extent to which anonymously owned companies were facilitating money laundering and tax evasion. The aim of the 5th Directive is to further improve transparency in relation to beneficial ownership.
Requirements of … more
As families become increasingly international, with family members located in different countries, it is vital that appropriate wills are drafted and, subsequently, regularly reviewed and amended to reflect any variation in circumstances. Often the jurisdictions where assets are located and/or where family members reside will be subject to change.
Are wills only applicable to wealthy … more
The UK non-domicile regime remains a relatively attractive option with UK non-domiciles (“non-doms”) continuing to have the opportunity to enjoy significant tax advantages for a period of up to 15 years.
Major reforms regarding how UK non-domiciles are taxed were introduced in April 2017. As detailed in the Dixcart Article: UK Tax Residence - Planning Opportunities, Case Studies and How to Get … 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
IN419 - Restarting the Clock for UK Non-Domiciles and Alternative Residence Options to Help Maximise Days Spent in the UK
The UK non-dom regime remains an attractive option for individuals seeking to move from their country of origin or current location. UK non-domiciles continue to have the opportunity to enjoy significant tax advantages for a period of up to 15 years.
Changes to UK Non-Dom Legislation
However, major reforms regarding how non-UK domiciliaries (“non-doms”) are taxed were implemented in April 2017 … more