What the UK Offers as a Tax Efficient Jurisdiction
One of the UK Government’s key ambitions has been to create the most competitive tax system in the G20. It has developed strategies to support, rather than hinder, growth and to boost investment.
Through the implementation of these strategies the Government is aiming to make the UK the most attractive location for corporate headquarters in … more
IN396 - What are the Key Changes to the Taxation of UK Residential Property for Non-UK Tax Residents?
The approach to the taxation of UK residential property has changed significantly over recent years and further changes have been announced. These changes mean that restructuring should be considered to avoid unnecessary taxation, charges and costs.
This Information Note summarises the main UK taxes that need to be considered when structuring the ownership of UK residential property by non-UK … more
IN351 - Isle of Man Exempt Funds: A Flexible Solution for Family Offices and High Net Worth Individuals
Isle of Man Exempt Schemes are an attractive option for family offices and high net worth individuals. Fund statistical data published by the Isle of Man Financial Supervision Commission at the end of 2014 indicated that as of September 2014 there were 150 Exempt Schemes registered in the Isle of Man, with a combined net asset value of $60.06bn.
What is an Isle of Man Exempt Scheme?
Isle of Man … more
On 26 October 2015 the Isle of Man launched initial legislation to regulate Crypto Currency, one of the first jurisdictions in the world to do so.
The priority is to ensure that firms operating in this sector are compliant with Anti-Money Laundering and Countering the Financing of Terrorism Regulations (AML and CFT).
The Isle of Man regulatory authorities are registering businesses in the … more
Families are becoming more and more mobile. There are many attractive residence schemes available around the world and family members are increasingly living in different countries. As this trend continues the management and control of family wealth across jurisdictions, in a tax efficient manner, becomes even more important.
Dixcart provides family office services from a number of offices, … more
Obligations of Cyprus Companies
A company registered in Cyprus must submit appropriate Audited Financial Statements and an Annual Return (HE32) to the Registrar of Companies and Official Receiver. The Audited Financial Statements for the year ending 31 December 2014 should be sent with the Annual Return 2015.
The Annual Return must be prepared within 14 days of the AGM and must be submitted … more
IN344 - Simon Kelly (Managing Director of Dixcart Isle of Man) Appointed Company Secretary to The International Sailing Federation
The International Sailing Federation (ISAF) is the world governing body for the sport of sailing, officially recognised by the International Olympic Committee.
What is the Role of ISAF?
ISAF is responsible for:
Acting as the controlling authority of the sport of sailing in all its forms throughout the world
Establishing, supervising, interpreting and amending the rules regulating all … more
IN401 - Dixcart Business Centres in Madeira: Serviced Offices for International Companies and for Co-Working
As an integral part of Portugal, Madeira is a full member of the European Union (EU), which makes activity from within the International Business Centre (IBC) of Madeira an extremely attractive proposition for international companies. A number of unique tax advantages are available to companies licensed to operate in the IBC of Madeira, including a corporate tax rate of 5%.
Dixcart has helped a … more
The OECD confirmed the final package of measures regarding the OECD G20 Base Erosion and Profit Shifting (BEPS) initiative on 5 October 2015.
The OECD objective is to address the gaps and mismatches where corporate profits have been “disappearing” or shifting to low or zero tax jurisdictions, where no real value creation has taken place.
This Article summarises the various reports that have … more
In March 2014 the Cypriot Tax Authorities issued new guidelines for the registration of private aircraft, making Cyprus one of the most attractive jurisdictions in the European Union.
The guidelines clarified the VAT treatment provided through the Cyprus Aircraft Leasing Scheme, and the potential VAT rate for aircraft registration in the EU can be effectively reduced to as low as 5% if … more
Nevis is a leading international Caribbean financial centre with a good reputation and excellent compliance standards.
What Advantages Does Nevis Offer as a Location for the Establishment of an International Business Corporation (IBC)?
Nevis does not levy VAT or other indirect taxes on IBCs and there is NO income tax, NO capital gains tax, NO wealth tax, NO death duty or inheritance tax. … more
0n 3 July 2015, the Portuguese Government confirmed a number of new rules relating to the Portuguese Golden Visa.
Background and Key Benefits of the Portuguese Golden Visa
The Portuguese Golden Visa Scheme enables non-EU individuals to gain the right to reside in Portugal and the right to travel within the Schengen Zone of 26 countries for a period of 5 years.
This can lead to permanent … more
The Isle of Man offers a financially attractive destination for a wide variety of businesses. Many companies have relocated to the island in recent years because, in comparison to other locations, the Isle of Man can be less expensive and it is also well regulated. This thriving jurisdiction plays host to a flourishing business environment.
The Isle of Man is situated in the Irish Sea, … more
IN380 - Foundations - Why? And Consideration of Various Jurisdictions: Guernsey, The Isle of Man, Malta and Nevis
Foundations are useful tools in terms of wealth management and asset protection. The jurisdictions of Guernsey, the Isle of Man, Malta and Nevis are attractive locations in which to establish a foundation. Each of these jurisdictions offer a number of potential advantages and the most appropriate jurisdiction will depend upon each specific situation.
Foundations: A Definition
A foundation is a … more
IN377 - The Isle of Man £50 Million Enterprise Development Fund (EDF) and Other Measures to Encourage Commercial Activity on the Island
In July 2015, the Isle of Man Government announced that an EDF would be made available and also detailed a number of other measures to assist businesses in the Isle of Man.
What is the £50 Million EDF?
The £50million fund, which will eventually be self-sustaining, will provide grant, loan and equity investment to new Isle of Man start-ups, existing expanding Isle of Man businesses and … more
An often forgotten tax concession introduced by the Isle of Man Government is the Key Employee Concession Programme, which was introduced in the 2004 Income Tax Act. It is an incentive by the Isle of Man Government to encourage real substance based businesses to establish themselves on the Isle of Man. This small piece of tax legislation will play an important role in the coming years, … more
Information and Communications Technology (ICT) is the broad term that covers the use of digital technology to help individuals and organisations to use information. This includes, for example, personal computers, smart phones, digital TVs, email and robots.
The Isle of Man has become a popular jurisdiction for leading ICT organisations and start ups. During the past 15 years this jurisdiction … more
Digital Currencies - Increasing Validation
To the spectators and professionals that considered digital currency to be a fad or a flash in the pan this initial reaction may now need to be reconsidered.
On 26 February 2015 the Bank of England (BOE) announced that they believe digital currency will revolutionise payment systems for banks. The BOE have announced that, as part of a wider macro … more
The Government of Malta introduced a new “Malta Residence and Visa Programme” at the end of August 2015. This programme is open to non-EU nationals and their dependants who wish to reside or stay indefinitely in Malta.
Each applicant must make a three-tier investment.
1. Contribution: A €30,000 payment to the Maltese Government AND
2. Qualifying Investment: … 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
Cyprus is becoming an increasingly attractive option for companies and individuals to consider relocating to. Attractive tax incentives exist and Cyprus offers a good corporate and residential location, enviable weather and a sound infrastructure.
On 9 July 2015 the Cyprus House of Representatives approved new tax laws which took effect on 16 July 2015. These changes … more
The global growth in FinTech has been rapid and the sector is predicted to continue this strong pattern of growth.
The European Commission defines FinTech as “the combination of innovative financial services and the availability of capital through the use of new (digital) technologies, such as crowdfunding”.
To ensure that the island is well placed to take advantage of the opportunities within … more
Malta has experienced a significant increase in the registration of new companies during the past few years and a consistent growth in Gross Domestic Product, boosted by the success of the financial services sector.
The growth in the financial services sector can be directly attributed to Malta’s generous system of tax refunds and unilateral relief, as well as Malta’s reputation as a compliant … more
The Maltese Government has introduced a new residence programme, which is available to non-EU individuals and enables them to reside or stay indefinitely in Malta.
The criteria for the programme are:
a €30,000 contribution to the Maltese Government; AND
an investment of a minimum €250,000 in Malta for at least 5 years; AND
the purchase of a property in Malta to the minimum value of €320,000, … more
Guernsey is one of the leading tax-free jurisdictions for the administration of international private wealth. Although a Crown Dependency and represented internationally by the UK Government, it is autonomous and has its own Parliament and its own tax regime. The island uses the British pound but also issues its own banknotes.
Guernsey’s finance industry benefits from a firm foundation of … more
Download our Dixcart Domiciles Brochure in Spanish
It is important that UK inheritance tax is taken into careful consideration, in particular by individuals who have assets in the UK. This Article examines how, with careful planning, some UK inheritance tax obligations can be mitigated for certain individuals.
What is UK Inheritance Tax?
UK inheritance tax (IHT) is a tax on money or assets held at death, and on some gifts made during a lifetime … more
A. Resumen de las principales ventajas que ofrece la jurisdicción de Suiza
¿ Que ofrece Suiza como ubicación para empresas o individuos ?
Situada en el centro de Europa.
Uno de los países de Europea de lo más estables económicamente y políticamente.
Una jurisdicción muy respetada con excelente reputación.
Más de 110 convenios de doble imposición.
Una larga historia y experiencia en … more
It is possible for a company to be incorporated in one jurisdiction and to be resident in another. In certain circumstances this can generate tax efficiencies.
It is very important to always ensure that the company is properly managed and controlled from the jurisdiction in which it is resident.
The jurisdictions of Cyprus, Malta and the UK present a number of opportunities, as detailed below. … more
A trust is created when an individual (the settlor) transfers ownership of certain assets to another individual or corporation (the trustee) who controls and manages those assets and uses them for the benefit of a specified individual or group of individuals (the beneficiaries).
Common Dilemmas Faced by Settlors and Trustees
Many high net worth individuals, when acting as settlors, … more
Fundações Multiformes da Nevis - Antecedentes
A Fundação Multiforme Nevis (NMFF) é uma entidade que possui a sua própria identidade legal, com capacidade de processar e de ser processada.
O regulamento da Fundação Multiforme da Nevis tornou-se lei em 2004, com o objetivo de ser refinado e desenvolvido com base na lei de fundação existente noutras jurisdições.
Caraterísticas e Benefícios … more
IN327 - EMPRESAS FIDUCIÁRIAS PRIVADAS: OS BENEFÍCIOS E AS VANTAGENS ADICIONAIS DE ESTABELECER UMA EMPRESA FIDUCIÁRIA PRIVADA [PTC] EM NEVIS
As famílias abastadas estão familiarizadas com as vantagens que um fundo fiduciário pode oferecer em termos de transferência de riqueza para a próxima geração de uma maneira eficiente. O Grupo Dixcart tem vasta experiência na prestação de serviços fiduciários profissionais em vários locais: Guernsey, Ilha de Man, Malta, Nevis e Suíça.
Existem muitos benefícios na utilização de um fundo fiduciá … more
The IV Regime of Tax Benefits for companies licensed to operate within the Madeira International Business Centre ("MIBC") was confirmed on 3 July 2015 and is now in force.
New companies can be incorporated in Portugal and authorised to operate under this new regime, with confirmed tax benefits that will remain unchanged until 2027, a period of 12 years.
Advantages of the New MIBC Tax Regime … more
Cyprus, Ireland and Malta are sovereign members of the European Union. Cyprus and Ireland both offer the very competitive corporate tax rate of 12.5% whilst Malta provides very generous tax rebates in respect to the external distribution of dividends, resulting in an ‘effective’ corporate tax rate of 5%.
The decision to use one of these three jurisdictions naturally depends on … more
IN372 - The Cyprus Yacht Scheme: April 2015 Revisions and a Further Potential Reduction in the VAT Payable
Guidelines issued in March 2012 made Cyprus one of the most attractive jurisdictions for yacht registration in the European Union.
On 30th January 2014 the Cyprus VAT Department updated the guidelines confirming the advantages of the Yacht Scheme and simplifying a number of the procedures.
What is New?
On 29th April 2015 the Cyprus VAT Department issued a new circular reducing the applicable … more
Cyprus offers a number of advantages as a location in which to work or retire, the climate and Mediterranean lifestyle being just two of the benefits. In addition Cyprus offers a number of financial incentives.
Please refer to the end of this Article for details regarding the criteria for tax residence in Cyprus and the income tax rates applicable in this jurisdiction.
Income Tax Relief … more
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.
Switzerland and the Use of Trusts
Switzerland does not have specific Trust Law, but recognised trusts by the ratification of The Hague Convention on the Law Applicable to Trusts (1985) on 1 July 2007. This recognition led to the amendment … more
Alternative project finance has become increasingly popular since the financial crisis of 2008. Businesses continue to diversify their funding arrangements by considering alternative finance structures. These structures can take a number of different forms, with the most common being equity and debt based alternative investments.
How Can Dixcart Assist with the Organisation of these … more
A Nevis Multiform Foundation (NMF) is an entity that has its own legal identity, with the ability to sue and to be sued.
The Nevis Multiform Foundation Ordinance became law in 2004 with the objective of refining and building on the foundation law existing in other jurisdictions.
Distinctive Features and Benefits of a NMF
The key distinctive feature of a Nevis Foundation in comparison to … more
Why Consider the Jurisdiction of Cyprus?
Cyprus is the third largest and third most populated island in the Mediterranean Sea. It is situated to the east of Greece and to the south of Turkey. Cyprus joined the European Union in 2004 and adopted the euro as the national currency in 2008.
Factors contributing to and enhancing the status of the jurisdiction of Cyprus include:
Cyprus is a member … more
The OECD is undertaking ongoing discussions regarding Base Erosion and Profit Shifting (BEPS).
The UK has acted swiftly and unilaterally as one of the first jurisdictions to introduce a Diverted Profits Tax and it is anticipated that many other jurisdictions will introduce similar provisions.
What is the UK Diverted Profits Tax?
On 1 April 2015 the UK introduced its new Diverted Profits Tax ( … more
In 2007 Cyprus adopted the Markets in Financial Instruments Directive (MiFID) which harmonised the regulation of investment services across the European Economic Area. This allows investment firms to operate throughout the European Union on the basis of authorisation in their member state (single passport).
In June 2009 the Cyprus Securities and Exchange Commission (CySEC) announced that Forex … more
Switzerland has a modern market economy and one of the highest per capita GDPs in the world. With a highly skilled labour force, Switzerland has low unemployment, and highly developed service and manufacturing sectors. Significant industries include: banking, insurance, machinery, chemicals (including health and pharmaceuticals), watches and other precision instruments, as well as a large … more
In November 2013 Malta introduced the Individual Investor Programme (‘IIP’), which is the only Passport Programme in the European Union that has been approved by the European Commission.
This programme, designed for non-EU individuals, has proved to be a resounding success, with over 400 applications received to date from individuals in more than 40 countries.
Malta is a full … more
Portugal is introducing new rules under the Golden Visa Residence Programme.
The new rules, which need to be confirmed by the Portuguese Parliament, are detailed below:
Investment in cultural or scientific researchThe investment of a minimum €350,000 in a project relating to cultural or scientific research will now qualify for a Golden Visa application.
Rebuilding or renewal of urban … more
HN45 - Good News for Portuguese Companies Established in Madeira and for Individuals Applying for the Portuguese Golden Visa
The European Commission has confirmed that companies licensed to operate in the Madeira International Business Centre (MIBC) will continue to enjoy tax benefits until 2027.
The 5% Corporate Income Tax (CIT) rate has been confirmed until 31 December 2027.
The benefit of the reduced CIT tax rate will be limited to a maximum ceiling, details of which are available on request.
There is no … more
From the second half of 2014, new, simplified, fast track procedures were introduced for issuing permits to non EU citizens (and their family members) who wish to invest in Cyprus by purchasing property.
The procedure should not take longer than two months from the date of the application. Once the permit is issued the applicant's passport is stamped and a certificate is provided indicating that … more
BEPS and Issues that Dixcart has been Identifying for Some Time
Substance based transactions - Base Erosion and Profit Shifting (“BEPS”) is coming!
For the past 10 years Dixcart has been actively encouraging clients to undertake substance based transactions, and guiding fellow professionals on how to move forward. Dixcart clients have been provided with operational business solutions and … more
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, … more
IN353 - EU Freedom of Establishment Provisions Upheld Versus a Challenge from an EU Member Tax Authority
The recent first tier tax tribunal case ‘Fisher & Ors Fisher’ has dealt a blow to both UK Transfer of Assets Abroad (“TAA”) Legislation and to Gibraltar.
Mr and Mrs Fisher and their son Peter had a UK bookmaking business. They established a Gibraltar company to which they sold their telebetting business.
The UK tax authorities raised assessments to tax the Fishers under UK TAA … more