IN293 - UK Controlled Foreign Companies Rules - And Certain Exemptions That Can Reduce Or Remove The Obligation To Pay UK Tax
The UK updated its foreign company (“CFC”) rules on 1 January 2013. A number of exemptions apply that can reduce or remove the obligation to pay UK tax.
A CFC is a non-UK resident company controlled by persons in the UK. Typically a CFC is a foreign subsidiary of a UK group, although corporate control is not required for a company to be a CFC.
The rules, which are essentially anti- … more
St Kitts & Nevis offers well-regulated and effective solutions for businesses around the world. It is an international financial centre with innovative corporate and wealth management solutions available to clients.
A number of jurisdictions are experiencing increased pressure from the wider international commercial community and/or measures taken by their own Governments. Nevis may be able to … more
Nevis offers a number of wealth planning opportunities which can provide certainty, flexibility and privacy to families who are planning for the future.
Numerous tax benefits are available to international companies, limited partnerships and trusts located in Nevis. These include NO income tax, NO social security tax, NO capital gains tax, NO wealth tax, and NO death duty or inheritance tax. … more
IN481 - Why Consider Using A Nevis International Business Company For Wealth Planning And Holding International Investments?
Nevis is a leading international Caribbean financial centre, with a good reputation and excellent compliance standards, making it well suited to holding international investments for wealthy families.
It can be a challenge for non-European investors to find an efficient and cost effective manner in which to make international investments. The use of a Nevis International Business Corporation ( … more
IN480 - St Kitts & Nevis Citizenship by Investment - A Second Passport That Can Assist With Mobility Around the World
A Second Passport - The Caribbean Solution for Alternative Travel Documents
In today’s ever changing world, freedom and ease of travel are becoming ever more important. Residents of many countries suffer from a lack of mobility, which most western countries take for granted.
Increasingly, wealthy non-EU individuals are applying for residence, and in some instances, citizenship in European … more
Wealth – a Responsibility
The transfer of wealth to the next generation is a critical issue. The ability and understanding of the next generation as to how to deal with the organisation and management of the wealth being passed to them is also a vital consideration.
A family’s financial wellbeing can be lost or reduced in disputes over control and management of the wealth. Unfortunately the … more
Trustees have never had more reason to ensure that their internal systems and controls are fit for purpose.
The main drivers behind the need to assess these are:
Increasing global scrutiny of wealth management structures by tax authorities
Global transparency and exchange of information
The establishment of beneficial ownership registers
The pressure on and from regulators to … more
In February 2017, Guernsey’s Government approved the establishment of a register of beneficial ownership information.
In implementing this initiative, Guernsey, along with a large number of other jurisdictions, is maintaining its commitment to meet international standards on tax transparency and is adopting the recommendations of the Financial Action Task Force.
This new Register … more
Historically, Portugal’s ‘brightest and best’ have looked for opportunities outside of Portugal. This was not necessarily because they wanted to, but because Portugal was more focused on keeping its head above water and on finding ways to leave the Economic Adjustment Programme agreed with the European Commission for the period 2010-2014 (the bailout programme).
Whereas in the past … more
IN476 - Trust / Foundation Hybrid Structure – An Asset Protection Structure for Internationally Mobile Individuals
Asset protection and wealth preservation continues to be a primary focus for high net worth individuals.
However, the ever increasing international mobility of individuals and their families means that the traditional Common Law jurisdiction solution of a Trust, or Civil Law jurisdiction solution of a Foundation may not, in isolation, prove to be optimum solutions for an individual’ … more
IN431 - The Isle of Man Alternative Banking Regime - Opportunities for Corporate Organisations and Representative Offices
The Alternative Banking Regime (ABR) in the Isle of Man can provide a number of opportunities for organisations. Discussions with clients and professional colleagues regarding the new regime have identified a number of potential applications and benefits of the ABR.
The ABR was introduced on 1 August 2016 and expands the existing Class 1 (deposit taking) banking licence to … more
Nevis and the British Virgin Islands (BVI) are countries within the Caribbean that offer well-regulated and effective solutions for businesses around the world. They are international financial centres offering clients innovative corporate and wealth management solutions.
A number of similar corporate services are available in the two jurisdictions but, due to recent Government rule changes in … more
Dixcart is licensed to provide fund administration services in Malta and in the Isle of Man.
We provide a comprehensive range of services in Malta including accounting and shareholder reporting, corporate secretarial services, fund administration, shareholder services and valuations.
The Benefits of Establishing a Fund in Malta
A key benefit in terms of using the jurisdiction of Malta for the … more
During the past decade Malta has consolidated its status as an international centre of maritime excellence. Currently Malta has the largest shipping register in Europe and the sixth largest in the world.
Malta has also become a world leader in terms of commercial yacht registration.
Yacht Registration in Malta
Commercial and pleasure yachts can be provisionally registered under the Malta flag … more
Malta offers five residence programmes to meet different individual circumstances. Some are appropriate for non-EU individuals while others provide an incentive for EU residents to move to Malta.
The five residence programmes and the tax benefits they can provide for individuals, where relevant, are detailed below.
INDIVIDUAL INVESTOR PROGRAMME
The Individual Investor Programme (IIP) … more
Beneficial Characteristics for the Location of an International Holding Company
The location of a holding company is an important consideration in any international structure where one of the objectives is to minimise the tax charged on the income flow.
Ideally the holding company should be resident in a jurisdiction which:
Has a good double tax treaty network, thereby minimising … more
As many of you know, each year Dixcart hosts a seminar. This year the topic was risk mitigation for family offices and corporates and was held at the Institute of Chartered Accountants in England and Wales (ICAEW) in London.
Risk is an increasingly important factor to mitigate for any business and for this particular seminar Dixcart chose to highlight the areas of geographic risk, family risk, … more
The Worldwide Disclosure Facility (WDF) runs from 5 September 2016 to 30 September 2018. It is designed to enable taxpayers to disclose a UK tax liability which relates wholly or partly to an offshore issue.
All other offshore disclosure facilities have now closed and this is the final opportunity for UK taxpayers to come forward before the Common Reporting Standard (“CRS”) information exchange … more
Cyprus is an attractive option for the relocation of both companies and individuals.
This island offers a warm climate, good infrastructure, convenient geographic location, membership of the EU, tax advantages for companies and incentives for individuals through the Cyprus non-dom regime.
The Cyprus House of Representatives approved new tax laws on 9 July 2015, which took effect on 1 … more
SA3 - Dixcart Group: More than 45 Years of Providing Professional Assistance to Internationally Mobile South African Families
South African families are currently experiencing a number of challenges. Increasingly, South African families are looking at international wealth protection strategies, business relocation options, and residency and citizenship solutions in the UK, Europe and elsewhere. Safety, security and currency volatility are big drivers, but political, economic and educational issues play their part too. … more
Dixcart Business Centres offer extensive serviced office capacity and are ideal for companies establishing themselves in a new location. Dixcart Business Centres are located in Guernsey, the Isle of Man, Madeira (Portugal), Malta and the UK.
Business Centres can offer a productive work environment and a cost effective option for organisations with international interests wishing to operate from … more
IN465 - 2-REG Channel Islands Commercial Aircraft Registry: Case History Highlighting the Advantages of Temporary Registration
Established in December 2013, “2-REG”, the Channel Islands Aircraft Registry, is the aircraft registry of the States of Guernsey. The nationality mark is ‘2’ followed by four letters, allowing for attractive registration marks.
There have been 94 registrations to date of lessor owned aircraft, corporate aircraft, including a Boeing 787-8 Dreamliner, and locally owned aircraft. The registry is … more
Cyprus Citizenship by Investment is rapidly becoming one of the EU’s most popular residence schemes.
A fast track procedure exists for non Cypriot citizens (and their families) to acquire Cyprus Citizenship by investing €2.5 million* in Cyprus.*€2.0 million in one set of circumstances as detailed in the financial criteria.
A non-Cypriot citizen who meets one of the financial criteria … more
The Isle of Man has long been known as a welcoming home to entrepreneurs and innovators. It has achieved this over the years by playing to its strengths, having strong communication with the private sector, supporting new ideas and new ways of thinking, changing legislation quickly, and because it has wanted to lead not follow. E-business, for example, has found a home in the Isle of Man, with … more
INSAA - Why Companies and Individuals are Relocating to the UK and a UK Entrepreneur Visa Case Study
During 2016 and also this year, an increasing number of Dixcart contacts are expressing 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," it is also because of the tax advantages available for both companies and individuals.
London was rated top city in the world in 201 … more
At the end of 2016 thousands of Cyprus companies were struck off – as the Cypriot Government recognised that many had been inactive for a number of years.
This Information Note considers why these companies were struck off and explains the relatively straightforward process for a company to be reinstated.
Why were Cyprus Companies Struck Off?
There are two reasons why the Cyprus Registrar of … more
Why is Guernsey an Attractive Jurisdiction for Companies?
There are a number of reasons why an individual may wish to migrate a company or foundation from its current jurisdiction of registration to the Bailiwick of Guernsey.
Guernsey is a well-regulated and internationally respected international jurisdiction. It is also a politically stable jurisdiction with its own autonomous government but … more
IN460 - What Financial Assistance is Available Through the Isle of Man Enterprise Development Scheme?
Entrepreneur Government Funding
The Isle of Man has long been known as the home of entrepreneurs and innovators. This has been achieved over the years by playing to its strengths; strong communication with the private sector, supporting new ideas and ways of thinking, changing legislation quickly, and because it has wanted to lead not follow.
E-business has found a home in the Isle of Man with … more
Individuals wishing to establish a company in the UK may, for a variety of reasons, consider the use of a Business Centre offering serviced office capacity, which will provide substance. Business Centres can offer a productive work environment and a cost effective option for organisations with international interests wishing to operate from a particular location.
A company establishing itself in … more
IN458 - Reduced Costs for the St Kitts & Nevis Citizenship by Investment Programme and Ability to Pass Citizenship to Future Generations
From the 1st of February 2017 a number of changes were made to the criteria required for a donation to the Sugar Industry Diversification Foundation (SIDF) to gain St Kitts & Nevis Economic Citizenship. These changes make this Citizenship option an even more attractive and cost effective proposition.
For additional information regarding St Kitts & Nevis Citizenship, please see: IN 308 – St Kitts … more
A lot of uncertainty has been generated within Europe following on from the Brexit vote, and certain other countries who are beginning to reassess their position within the EU. This is having an impact on the marine industry, with a number of vessel owners seeking to reflag ships and yachts.
The choice of flag registration is an important decision and a jurisdiction must be selected that … more
South Africa is one of the most sophisticated and promising emerging markets globally.
The potential offered by the South African economy is evident in its diversity of sectors and industries. It has a modern and extensive transport infrastructure and labour costs are priced competitively.
These factors, together with the country's significant natural resources, have made it a popular country … more
Guernsey’s innovative legislation on Image Rights (IR) became law in November 2012 and it remains the only jurisdiction in the world to date where an individual, group or legal entity can register their Image Rights on a public register.
Registrations have been steady since that date, with currently 64 IR registrations for individuals and entities from a broad range of human activity, including … 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
Con la creciente movilidad de los empresarios y personas ricas por todo el mundo, por razones comerciales o personales, existe una mayor necesidad de proveer una base fuera del país de origen o de residencia de las familias de alto patrimonio para coordinar el desarrollo de sus intereses comerciales.
Una base de impuestos neutral
Una base suele establecerse en una jurisdicción de … 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.
Dixcart in Switzerland and Trust Services
The Dixcart office in Switzerland is a member of the Swiss Association of Trust Companies (SATC) and is registered with the Association Romande des Intermediaires Financiers in Switzerland (ARIF). … 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, bankers, … more
Switzerland is an attractive location for Intellectual Property (IP) companies. It combines a proactive business and tax approach with a stable political and economic environment.
Holding and administering IP rights in one jurisdiction under one central IP company considerably simplifies the management of group IP rights and enables stronger control.
Switzerland: A Formidable Intellectual … more
Why Use a UK Company?
The UK Government has introduced many changes to make the UK tax system more competitive. This has led to the return of UK holding companies, the re-shoring of manufacturing and increased UK based research and development (R&D).
United Kingdom (UK) entities have a respectable international image and can be used tax efficiently for cross border trading and as international … more