IN294 - Cyprus, Madeira, Malta and the UK as Holding Company Jurisdictions

Ideal Characteristics for the Location of an International Holding Company

The location of a holding company is an important consideration in any international structure where the objective is to minimise the tax charged on the income flow.  Ideally the company should be in a jurisdiction which: 

Has a good double tax treaty network, thereby minimising withholding taxes on dividends received. … more

JNA: Formation of Companies in Guernsey

Updated 27 April 2016

WHY USE GUERNSEY?

Guernsey is a leading international financial centre with a good reputation and excellent standards. The Island is also one of the leading jurisdictions providing international insurance services and is developing a base from which internationally mobile individuals can be organised. Factors contributing to and enhancing the status of this jurisdiction … more

IN229 - An Isle of Man Exempt Fund - A Vehicle to Raise Capital for Use by Property Portfolios

Funding is at the core of all successful business and the ability to raise capital when needed is vital to the survival and development of a good idea or sound business. 

The 2008 credit crisis demonstrated that reliance on third party lenders can no longer be assured, particularly where the underlying assets are relatively illiquid in nature. An example of such assets would be a long term … more

IN324 - Image Rights - Register in Guernsey Now In Anticipation of Future Fame

Many well-known individuals, including national sporting heroes and recording artists, have already registered their image rights in Guernsey to maximise the potential earning value of their personal brand.

Individuals with the potential ability to generate significant wealth from the use of their image, in addition to their earnings, should register their image rights. It can be even more … more

IN340 - A Residence Scheme for Every Situation and to Meet Every Need

Dixcart Domiciles can assist individuals and their families to gain residence in a number of different countries, and in some cases it is possible for citizenship to also be obtained. 

A number of case studies are detailed below, outlining situations where Dixcart has been able to help individuals who were either seeking to move overseas, wishing to have an option to move abroad in the future, … more

IN329 - Immigration to the Isle of Man: The Benefits, Tax Efficiencies and Potential British Citizenship

The Isle of Man and British Citizenship

One of the key advantages that immigration to the Isle of Man can offer is that it entitles the successful applicant and his family to receive British Citizenship, if all of the relevant conditions are met. Subsequently an application can be made for a British passport.

Dixcart and Immigration to the Isle of Man

Dixcart is experienced in assisting many … more

IN328 - Taxation of Crypto Currency, Developments to Significantly Increase Transparency and an Update on Sector Activity in the Isle of Man

Taxation of Crypto Currency

The UK and the Isle of Man are two of only a few countries that have specific guidance on the tax treatment of Crypto currencies.

HMRC (UK) Taxation Briefing and VAT Treatment

Earlier in 2014 United Kingdom HM Revenue and Customs released a briefing on the taxation of Bitcoins and Crypto currencies.  It indicates that they will essentially be treated in the same way … more

IN322 - Isle of Man - The Location of Choice for "FinTech" Companies

"FinTech" is the technology relating to the delivery of financial services, with the client generally being a financial institution.  FinTech includes the holding of financial data on clients and the distribution of digital products, where connectivity,  security and legislative protection are all important factors.   

Types of FinTech activity include:

Cash and investment management … more

IN316 - The Isle of Man - The Benefits for Business and Family

The Isle of Man offers a highly attractive business infrastructure and also provides a stable, secure and accessible environment for individuals and families. 

This island is home to a number of diverse industries, including; aerospace, banking, financial services, manufacturing, ship and aircraft registration, the space industry and film production. 

WHY THE ISLE OF MAN FOR BUSINESS?

Location: … more

IN315 - Digital Currencies - The Isle of Man Leads the Way

Digital Currencies and the Isle of Man

Several digital currency (crypto currency) businesses are expressing interest in establishing themselves on the Isle of Man.  A number of major e-gaming companies are already located on the island and the Isle of Man has solid experience in hi-tech industries, a mature infrastructure and range of professionals to support digital currency organisations.

In … more

IN312 - Aircraft Registration: Guernsey, Isle of Man, Malta and Portugal

Dixcart provides aircraft registration services in a number of jurisdictions. These jurisdictions have registries which offer a variety of advantages and tax efficiencies. 

Dixcart can advise on aircraft registration and help coordinate the aircraft registration process in: Guernsey, the Isle of Man, Malta and Portugal. This can include establishing and administering the relevant ownership … more

IN317 - An Important Guide: Moving to the United Kingdom

CONSIDERATION OF THE ROUTE CHOSEN TO ENTER THE UK

Immigration Considerations

When first coming to live in the UK it is important to ensure that your immigration status will allow you to do what you wish to do; will it allow your family members and any staff to come to the UK to study or work? Will it allow you and your family members to remain in the UK in the long-term if you wish to do so? … more

IN303 - Reasons Why Companies and Individuals are Relocating to the UK and a Case Study for the UK Entrepreneur Visa

Since 2013 an increasing number of Dixcart contacts have expressed 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" but also because of the tax advantages that are available to both companies and individuals.

Tax Advantages Available to UK Companies 

One of the … more

IN338 - Moving to the UK - An Attractive Location

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

JNC: Summary of the Formation and Maintenance Obligations of Portuguese Companies in Madeira

Why Use Madeira? 

Companies licensed to operate in the International Business Centre (IBC) of Madeira enjoy a number of tax advantages, under the IV Regime of Tax Benefits, which are guaranteed to the end of 2027. 

Corporate tax rate of 5%.

Madeira is an integral part of Portugal and therefore a full member of the European Union.

Access to the Portuguese Double Taxation Treaties … more

IN326 - Reasons to use a Cyprus Company

Cyprus is an attractive international jurisdiction with a very good holding company regime. Dixcart has an office in Limassol and can therefore efficiently organise the formation and management of companies in Cyprus.

Approximately 8,000 new companies were registered in Cyprus between January and September 2014.

Detailed below are some of the benefits available to companies established in … more

IN307 - The Portuguese Non Habitual Residents Regime

Background

The Portuguese Non Habitual Residents (NHR) regime presents a number of tax saving opportunities for individuals considering a move to Portugal. This regime is available to both EU and non-EU citizens.

This tax regime was originally introduced in 2009 and continues to attract, to Portugal, qualified foreign residents engaged in high added value activities, and other high net worth … more

IN339 - EU Parent-Subsidiary Directive - Greater Need to Demonstrate Commercial and Economic Links

ECOFIN has Reached Political Agreement on an Amendment to the Parent-Subsidiary Directive

The Parent-Subsidiary Directive (2011/96/EU), adopted in November 2011, is intended to ensure that profits made by cross-border groups are not taxed twice, and that such groups are thereby not put at a disadvantage compared to domestic groups.  It requires member states to exempt profits that have been … more

Switzerland has Voted to Retain the Lump Sum System of Taxation

At the end of November 2014 the Swiss Government voted to maintain the lump sum system of personal taxation in the cantons where it is in operation*.

The lump sum system will be amended from 1 January 2016. The new law will introduce the following changes:

The lump sum income will be to at least seven times (currently five times) the rental value or the annual rent of the Swiss residence. … more

IN335 - Why is a Madeira (Portuguese) Company an Effective and Tax Efficient Solution?

Through legislation approved in Lisbon, and in Brussels by the European Commission, tax advantages have been enjoyed for several years by Portuguese companies registered in Madeira. This is known as the International Business Centre of Madeira (‘IBC’) Legislation.

The tax advantages apply to industrial and manufacturing activity within the  geographical area of the IBC of Madeira, as well as … more

IN334 - The Cyprus Yacht Scheme - Attractive Potential Reduction in VAT Payable

Guidelines issued in March 2012 made Cyprus one of the most attractive jurisdictions for yacht registration in the European Union (EU).

This Yacht Registration and Leasing Scheme effectively reduces the VAT rate for yacht registration in the EU to as low as 4.6% and the VAT rate on lease payments to as low as 3.8%.

On 30 January 2014 the Cyprus VAT Department updated the guidelines, confirming … more

IN330 - Portuguese Holding Companies - A Tax Neutral Holding Structure

In January 2014 Portugal implemented a major and ambitious reform of its Corporate Income Tax Code (CIT Code).

One of the features of the new CIT Code was the introduction of a participation exemption method for dividends and capital gains. This provides a tax exemption on dividends and capital gains at the level of the company and a withholding tax exemption on outbound dividends, as long as … more

IN331 - Portuguese Patent Box and Madeira Companies - Additional Tax Efficiencies

Portugal introduced a new Corporate Income Tax Code at the beginning of 2014 and at the same time put in place a Patent Box Regime which provides benefits for Intellectual Property (IP) activities.

The Advantages of the Portuguese Patent Box Regime

Only 50% of the gross income resulting from contracts exploiting patents, industrial designs or models (or other IP rights which are protected) … more

INPT1a - Portuguese Holding Companies - an Attractive Ownership Solution for Trading Companies in the Netherlands

In January 2014 Portugal implemented a major and ambitious reform of its Corporate Income Tax Code (CIT Code).

One of the features of the new CIT Code was the introduction of a participation exemption for dividends and capital gains. This provides a tax exemption on dividends and capital gains at the level of the company, and a withholding tax exemption on outbound dividends, as long as certain … more

INPT1c - Portuguese Holding Companies - an Attractive Ownership Solution for Trading Companies in Luxembourg

In January 2014 Portugal implemented a major and ambitious reform of its Corporate Income Tax Code (CIT Code).

One of the features of the new CIT Code was the introduction of a participation exemption for dividends and capital gains. This provides a tax exemption on dividends and capital gains at the level of the company, and a withholding tax exemption on outbound dividends, as long as certain … more

INPT1b - Portuguese Holding Companies - an Attractive Ownership Solution for Trading Companies in Belgium

In January 2014 Portugal implemented a major and ambitious reform of its Corporate Income Tax Code (CIT Code).

One of the features of the new CIT Code was the introduction of a participation exemption for dividends and capital gains. This provides a tax exemption on  dividends and capital gains at the level of the company, and a withholding tax exemption on outbound dividends, as long as certain … more

IN327 - Private Trustee Companies: The Benefits and the Additional Advantages in Establishing a PTC in Nevis

Wealthy families are familiar with the advantages that a trust can offer in terms of transferring wealth to the next generation in an efficient manner. The Dixcart Group has extensive experience in providing professional trust services in a variety of locations: Guernsey, Isle of Man, Malta, Nevis and Switzerland.

There are many benefits to using a trust managed by a professional trustee with … more

IN321S - CARACTERÍSTICAS Y VENTAJAS DE LA HOLDING ESPAÑOLA

La Holding española (Entidad de Tenencia de Valores Extranjeros - ETVE) fue introducida en 1995. Ha demostrado ser un vehículo muy atractivo para inversionistas extranjeros debido a los incentivos fiscales que puede proporcionar. 

La ETVE beneficia de los convenios de doble imposición suscritos por España y de las Directivas europeas, tales como la Directiva Matriz-Filial y la Directiva Fusión. … more

IN321 - Features and Advantages of a Spanish Holding Company

The Spanish international holding company (ETVE) was introduced in 1995. It has proved a popular structure internationally, due to the tax efficiencies that it can provide. 

An ETVE benefits from EU Directives such as the Parent-Subsidiary Directive and the Merger Directive. An ETVE can also take advantage of the network of Double Tax Treaties that Spain has with other countries.

Shares must be … more

IN284 - Cyprus - Moving Forward

Whilst Cyprus endured a banking crisis in 2013, the jurisdiction remains an attractive international business centre.

The EU bailout was primarily the result of an over sized banking sector in Cyprus that was heavily exposed to Greek debt. A "good" and a "bad" bank were created and losses in these two banks were imposed on the unsecured deposits of the two principal banks on the island. It is … more

IN325 - An Explanation of the Unique Features of Guernsey Limited Liability Partnerships

The Limited Liability Partnerships (Guernsey) Law 2013 came into effect in May 2014 and expands the range of Guernsey structures available for professionals to provide solutions to their clients. 

Key Characteristics of a Guernsey Limited Liability Partnership

A Guernsey LLP is a body corporate with unlimited capacity and its own legal personality, separate from that of its members. This is a … more

IN309 - How to Obtain a Passport through the Maltese Individual Investor Programme

Malta offers a number of interesting residence programmes, such as The Global Residence Programme, The Highly Qualified Persons Scheme and The Malta Retirement Programme. 

For many the most attractive programme is The Individual Investor Programme (IIP) as this enable non-EU citizens to obtain a Maltese passport.

During the first quarter of 2014 the Maltese Government and the EU confirmed the … more

IN319 - Setting Up a Business in the UK: The Legal Considerations

Starting a new business is very time consuming, especially if the UK is new to you, with different rules and regulations. Dixcart Legal Limited (Dixcart Legal) can assist with your legal requirements in a seamless way (as well as providing access to tax, IT, and payroll teams if required) so that you can focus your time on building your business.  

Set out in this brief note are issues to … more

HN44 - Cyprus - A Summary of Advantages

Dixcart is celebrating two years in Cyprus and continues to assist clients with the management and control of companies on the Island.  

The Cyprus corporate tax rate remains an attractive 12.5% and the Island offers many additional advantages for business:

Holding Company Regime

No withholding tax on dividends, interest and royalties.

No tax on dividend income.

No tax on income or gains … more

HN43 - Résidence et domicile portugais - Conseils et assistance professionnels depuis Genève

Le Portugal a récemment adopté une réglementation extrêmement attrayante liée à la résidence au Portugal pour Européens et Non–Européens.

Avocate – fiscaliste suisse et administratrice de Dixcart Suisse depuis plus de 10 ans, je me ferai un plaisir de vous informer et de vous assister en français, anglais et espagnol. 

Golden Visa: Un régime attractif qui offre la possibilité aux Non-Europé … more

JNG: Malta Jurisdiction Note

WHY USE MALTA?

The Republic of Malta is an archipelago consisting of the three inhabited islands of Malta, Gozo and Comino.  The Maltese islands are situated in the middle of the Mediterranean Sea, about 100 km south of Italy. 

Factors contributing to and enhancing the status of the jurisdiction include:

Malta is a member of the EU and therefore has access to European Union Conventions. 

It … more

IN308 - St Kitts & Nevis Economic Citizenship - Distinctive Advantanges

The St Kitts & Nevis Economic Citizenship Regime offers a number of benefits which are detailed below. In addition the scheme offers several distinctive features which are also highlighted.

A key advantage of this residence regime is that individuals can obtain a St Kitts & Nevis passport which has full Schengen travel rights throughout Europe.

Why Consider Moving to St Kitts & Nevis?

The … more

IN306A - The New Portuguese Corporate Income Tax Code (Long Version)

Portugal has already introduced two new regimes to encourage wealthy foreign individuals to move to and/or invest in Portugal; the Non-Habitual Resident Regime and the Golden Visa Regime. Both schemes are proving successful with a significant positive impact on the share of foreign investment as a percentage of Portugal’s GDP.

In addition, Portugal has now implemented a major reform of its … more

IN306 - The New Portuguese Corporate Income Tax Code (Summary Version)

Portugal has implemented a major reform of its corporate tax code, which has increased the attractiveness of Portugal as an international jurisdiction for domestic and foreign investors.

The key advantages of the new tax code are detailed below and more detailed information is available in our Information Note 306A or on request.

Worldwide Participation Exemption Regime: Applicable to Capital … more