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
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.
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
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
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
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
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
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
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 are governed by the ‘Civil Act’ and the ‘Voluntary Organisations Act’ and are constituted as a … more
FEATURES WHICH MAKE ISLE OF MAN FOUNDATIONS ATTRACTIVE ASSET PROTECTION VEHICLES
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
Last Updated: July 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 freedom … more
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
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
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
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
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
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
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
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
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
Nevis is a leading international Caribbean financial centre with a good reputation and excellent standards.
The jurisdiction of St Kitts & Nevis offers options in terms of international companies, private trustee companies and international trusts and foundations. It also offers an attractive passport scheme (recipients do not need to reside in St Kitts & Nevis), which is of … more