• IN450 - A Move of Residence

    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 of movement is not the … 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

  • 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

  • IN437 - Key Characteristics and Advantages of Portuguese Holding Companies

    Since 2014 approximately 100,000 companies have been incorporated in Portugal, representing a 10% increase in comparison to 2011, when Portugal was granted an international bailout package, which culminated in a “clean exit” in May 2014.

    This significant increase in incorporations has been driven mainly by foreign companies seeking a jurisdiction in which the quality of life matches the … more

  • IN434 - CRS and Transparency - Clients Should Assess and Act Now

    The 2004 Disclosure of Tax Avoidance Schemes (DOTAS), introduced by the UK in 2004, was one of the first pieces of legislation, globally, to address the topic of transparency and disclosure.

    With the on-going implementation of the OECD’s Common Reporting Standards (CRS), the prescient title of UK HMRC’s 2013 publication ‘No Safe Havens’ is more relevant than ever.

    Commercial and wealth … more

  • IN436 - Restarting the Clock for Non-UK Domiciles: Why Cyprus, Malta and Portugal are Attractive Jurisdictions to Consider for Relocation

    The UK offers an attractive tax regime for up to 15 years for individuals who are resident in the UK but do not have a UK domicile.

    Individuals who are UK resident, but not UK domiciled, do not have to pay UK tax on their foreign income and gains, as long as these sums remain outside of the UK.

    Individuals may choose to structure their tax affairs so that they cease to be UK tax resident for a … more

  • IN433 - Switzerland: an Option to Consider for Individuals Seeking to Relocate from the UK

    The UK is currently going through a period of considerable change, a significant element of which has been caused by the recent Brexit vote. Whilst this creates opportunities for some, the ensuing uncertainty is causing concern for a number of current UK resident individuals.

    A number of revisions (due to be introduced in April 2017) have been also proposed regarding the status of UK nom-doms. … more

  • IN432 - Acquiring Property Through a Cypriot Company

    Property in Cyprus can be purchased through a Cypriot company and the investor can benefit from the advantages available to Cypriot corporations. There are a number of capital gains tax exemptions, which make investing in Cypriot property attractive and Cypriot corporation taxes are also competitively low.

    For the purposes of this Article, property is defined as both residential and commercial … more

  • INPT2 - Chipre – Obtenção da Cidadania Através de Investimento

    Concessão da Cidadania

    A obtenção da cidadania no Chipre através de investimento, é um procedimento rápido e fácil, aplicável a cidadãos não cipriotas e aos seus membros familiares.

    Participando neste programa, o aplicante e os seus membros familiares obterão o passaporte cipriota. De realçar que não obterá apenas uma permissão de residência ou um visa, mas sim plena cidadania de um Estado  … more

  • IN430 - What are the Major Factors Non-UK Residents Should Consider When Investing in UK Commercial Property?


    Whilst there have been several recent taxation changes relating to UK based residential property (explained in Dixcart Article IN396) the taxation regime for UK based commercial property remains largely untouched.

    This, combined with the reducing UK corporation tax rate to 17% by 2020, mean that the UK commercial property market continues to be an interesting investment for current … more

  • IN429 - Migration of Companies To Nevis – Why and How

    Why Migrate a Company to Nevis?

    There are a number of reasons why you might consider migrating an existing company to the jurisdiction of St Kitts & Nevis:

    Nevis is a well-regulated jurisdiction which is independent and offers a stable political and economic environment.

    Nevis applies Common Law.

    Nevis does not have public or Governmental registers for directors, shareholders or … more

  • IN388 - What Does the Jurisdiction of Switzerland Offer to Companies and Individuals?

    Switzerland has a unique position within Europe and one of the world’s most stable economies based on finance, banking, technology and commodities. Bordering Austria, France, Germany, Italy and Liechtenstein, Switzerland has a long and strong tradition of political and military neutrality.

    What does Switzerland Offer as a Location for a Company or an Individual?

    There are a number of reasons … more

  • IN426 - Why Choose Nevis for International Business Corporations?

    This Article provides a summary of why Nevis International Business Corporations (IBCs) can be beneficial within the international arena.


    Nevis has no Public or Government Registers for directors, shareholders or beneficial owners.  All information is maintained privately and securely at the Registered Office by the Agent. 

    Nevis is a well-regulated jurisdiction which is … more

  • IN425 - The Potential Tax Efficiencies Offered by UK Business Investment Relief for Non-UK Domiciled Individuals

    What is UK Business Tax Relief and What are the Tax Advantages?

    UK Business Investment Relief (BIR) was introduced in 2012.

    The key advantages provided through BIR are:

    A non-UK domiciled individual who is taxed on the remittance basis can use ‘idle’ overseas funds in the UK, as long as the remittance is channelled into a qualifying investment with a qualifying underlying UK commercial … more

  • IN424 - Why Consider Cyprus as the Location for an Alternative Investment Fund?

    A Cyprus Alternative Investment Fund (AIF) is a collective investment which raises external capital from a number of investors with a view to investing it for the benefit of those investors. It does not need to be licensed as an Undertaking for Collective Investment in Transferable Securities (UCITS).

    Alternative investments include hedge funds, managed futures, real estate, commodities and … more

  • IN423 - Family Office Support

    With the increasing movement around the world of business people and wealthy individuals, for either commercial or personal reasons, there is an increased need for the provision of a base outside individuals’ countries of origin and outside of their countries of acquired residence to coordinate the development of business interests.

    A Tax Neutral Base

    A base is often most appropriately … more

  • IN422 - Family Offices and Cell Company Investment

    Guernsey pioneered the concept of Cell Companies initially to provide for segregated captive insurance. There entities are also referred to as Segregated Cell Companies and Segregated Portfolio Companies.

    Creative Uses of Cell Companies

    Since the introduction of the Protected Cell Company (PCC), the cell company concept has been further enhanced by the innovation of the Incorporated Cell … more

  • JNB2: Formation of Companies in the Isle of Man - Companies Act 2006

    Why Use the Isle of Man?

    Isle of Man companies benefit from a zero rate of tax on trading and investment income.  They are also able to register for VAT, and businesses in the Isle of Man are treated by the rest of the EU for VAT purposes as if they are in the UK.

    Isle of Man companies are therefore particularly useful for:

    Holding investment portfolios and participations in other companies. … more

  • JNB1: Formation of Companies in the Isle of Man Companies Act 1931 (as amended)

    Isle of Man companies benefit from a zero rate of tax on trading and investment income.  They are also able to register for VAT, and businesses in the Isle of Man are treated by the rest of the EU for VAT purposes as if they are in the UK.

    Isle of Man companies are therefore particularly useful for:

    Holding investment portfolios and participations in other companies. This is due to the zero … more

  • IN391 - Portuguese Golden Visa and the Non-Habitual Residents Tax Scheme - Making Portugal an Attractive Location for Residence

    Since the introduction of Portugal’s “Golden Visa” and a special tax regime for non-habitual residents, Portugal has become a destination of choice for many non-EU nationals.

    The Golden Visa enables non-EU residents to not only be resident in Portugal, but to also move freely within the Schengen Zone.  The “Non-Habitual Residents Regime” means that they can also enjoy low taxes or, in some cases, … more

  • IN421 - The Isle of Man - Your New Island Home?

    The beautiful Isle of Man is situated in the heart of the Irish Sea, centrally located between England, Ireland, Scotland and Wales.  Whilst the island may be small, just 572 km2, with its rugged coastline and rolling hills it can give you and your family space to breath, relax and enjoy what island life has to offer. 

    The Isle of Man has been a self-governing Crown Dependency since 1866, and … 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

  • IN420 - Sark - Channel Islands and Tax Transparency

    Sark, in the Channel Islands, is located close to Jersey, Guernsey and Alderney and is a unique and unspoiled island with no airport or cars.

    It is a quiet tourist destination with little other industry to detract from the island’s stunning natural beauty, with a small population enjoying an exceptional rural quality of life.

    Tax Residency Confirmation

    With growing moves toward international … more

  • IN417 - Why the Choice of Trustee is so Important

    The job of trustee is an onerous one, which makes choosing the right trustee extremely important.

    The name of the arrangement - ‘trust’, provides a clear indication as to the most important emotion that the settlor must have with respect to the trustee.

    The Role of Trustee

    The settlor of a trust gives the legal ownership of the assets put into the trust to the trustee, who looks after those … more

  • IN393 - Moving to Guernsey: The Benefits and Tax Efficiencies

    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 benefits of … more

  • IN414 - Make Sure You Are Ready For The Common Reporting Standard (CRS)

    The Common Reporting Standard (CRS) is based on FATCA principles and will result in a substantial increase in the flow of cross-border personal financial information.

    FATCA (Foreign Account Tax Compliance Act) was introduced by the United States in 2010. FATCA requires financial institutions outside the US to report information regarding financial accounts held by their US clients to the … more

  • IN415 - Taxation of Trusts in Portugal and the Implications for Non Habitual Residents

    When individuals who are potential beneficiaries of trusts are planning to move to Portugal and will become Non Habitual Residents (NHRs) they need to review the trust position prior to any future distributions being made.


    Legislation was approved in Portugal at the end of 2014 regarding the taxation of fiduciary structures, which includes trusts.

    Distributions made by fiduciary … more

  • IN413 - The Cypriot Notional Interest Deduction Regime and How It Can Be Of Benefit

    Cyprus has introduced a Notional Interest Deduction (NID) in relation to new equity capital. This is effectively a tax allowable deduction against the taxable profits of a company.

    The change in law makes the tax treatment of equity finance the same as that for finance by borrowing. A key benefit of this change is that a parent company injecting capital will not receive interest from the funds … more

  • IN409 - CROWD FUNDING - Professional Trustee Services for Commercial UK Fundraising and Borrowing Arrangements

    Alternative project finance continues to remain a popular route to commercial fundraising, particularly in the UK commercial property development industry. 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, with UK … more

  • IN410 - Persons with Significant Control (PSC) Register for UK Companies

    From 6 April 2016 UK companies and limited liability partnerships must keep a register of Persons with Significant Control (PSCs).

    From 30 June 2016 PSC details need to be included on a company’s annual confirmation statement (which replaces the current annual return).  This is a public document.

    Who is a PSC?

    You are a PSC if you meet one of the following conditions:

    Hold directly or … more

  • IN408 - The Use of a Malta Holding Company to Hold Shares in a Swiss Company - The Advantages Available

    Malta has long been considered a leading holding company jurisdiction due to its participating holding exemption on dividends and capital gains, as well as its lack of withholding tax on payments to shareholders.

    Switzerland has also been a favoured location for international trading and holding companies as these companies enjoy beneficial rates of taxation as well as access to Switzerland’s … more

  • IN407 - Isle of Man - The Home of the "Fintech" Entrepreneur

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

    Often these companies will have technology that negates the need for or … more

  • PT1 - A Organização De Um Fundo Em Malta - Os Benefícios

    Dixcart fornece serviços de administração de fundos em Malta e na Ilha de Man. 

    A partir de Malta, podemos fornecer uma vasta gama de serviços, incluindo contabilidade e elaboração de relatórios financeiros, serviços administrativos empresariais, administração de fundos, avaliações e serviços financeiros.

    Os Benefícios da Criação de um Fundo em Malta

    Um dos principais benefícios de se utilizar … more

  • JND: Formation of an International Business Corporation in Nevis


    Nevis is a leading international Caribbean  finance centre with a good reputation and excellent standards. Factors contributing to and enhancing the status of this jurisdiction include:

    Nevis as an International Business Centre

    Nevis does not levy VAT or other indirect taxes on Nevis International Business Corporations (IBCs) and there is no income tax, capital gains tax, … more

  • IN406 - UK Tax Residence - Planning Opportunities, Case Studies and How to Get it Right

    Major reforms regarding how UK tax resident, non-UK domiciliaries (“non-doms”) are taxed were introduced in April 2017.

    The changes impact on individuals who have been tax resident in the UK for 15 years or more.

    The Attractive Remittance Basis of Taxation will Continue for Many Non-UK Domiciliaries

    The availability of the remittance basis of taxation for non-UK domiciled individuals who have … more

  • IN405 - The Opportunities Available Through Redomiciling a Company to Cyprus

    Redomiciliation of companies in to and out of Cyprus became possible in 2006, when the House of Representatives enacted a new law which amended the Company Law. This made it possible to transfer the domicile of a company either in to or out of Cyprus.

    In conjunction with the competitive tax advantages that Cyprus offers, including the lowest corporate tax rate in the EU, this law further … more

  • IN404 - The Potential of Using a Managed Trust Company in Nevis

    The Concept

    A number of families and organisations have considered creating their own trust company in a tax-efficient jurisdiction, such as Nevis, but have concluded that the expense involved in setting up such an operation would not be justified.

    An alternative is to establish a managed trust company. 

    The benefits of an internal trust company can be enjoyed without incurring the high … more

  • IN392 - Moving to Malta - An Attractive EU Location

    Moving to Malta – An Attractive EU Location

    Malta offers five residence schemes to meet different individual circumstances. Each scheme provides an opportunity for individuals to move to Malta and/or to gain Maltese citizenship and, subsequently, a Maltese passport.


    Malta is an appealing EU jurisdiction offering a temperate climate and attractive beaches. Located in the … more