The jurisdiction of Guernsey offers a very pleasing environment to live in as well as very attractive personal and corporate tax regimes.
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.
Guernsey – a Tax Efficient Jurisdiction
Guernsey is a leading international financial … more
Trust structures are generally associated with estate and succession planning for private client engagements, because of the advantages and safeguards that a well-structured trust can provide.
Use of a Trust as Part of Corporate Processes
Trusts, however, can also play an important role within corporate transactions. Consider the planning phases leading up to an initial public offering (IPO), … more
The Maltese Income Tax Act exempts royalties, advances and similar payments arising from copyright, from tax.
Exemption in Respect of Certain Copyright Income
The income tax exemption with respect to royalties received from certain types of ‘copyrightable’ intellectual property, in relation to; books, film scripts, music and art.
The Income Tax Act exempts royalties, advances and similar … more
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.
Beneficial Characteristics for the Location of an International Holding Company
Ideally the holding company should be resident in a jurisdiction which:
Has a good double tax treaty network, thereby minimising … more
INSWT Switzerland: Asset Protection, Double Taxation Agreement and an Attractive Location for Residence
What does Switzerland Offer Businesses, Individuals and Families?
Located in the centre of Europe
Economic and political stability
A well respected jurisdiction with an excellent reputation
Most ‘innovative’ country in the world for nine consecutive years
Lengthy history of expertise in finance and business
Premier destination for international investment and asset protection
High regard … more
Threats and opportunities have always existed and never more so than in this rapidly changing world.
Many countries are experiencing significant political and economic change. The jurisdiction of St Kitts & Nevis provides an opportunity for individuals to hold a second passport, even if the immediate intention is not to relocate to the Caribbean.
Key Benefits Offered By Holding a St Kitts & … more
The EU Council’s ‘base erosion and profit shifting’ (BEPS) action plan defines the requirements to be met, by jurisdictions wishing to maintain low tax regimes for businesses undertaking ‘specified’ activities, in order to demonstrate that they have sufficient substance in that particular jurisdiction.
Requirements include; ‘core income generating activities’ must take place in the … more
On 30 October 2019, the Ukraine ratified changes to two Double Tax Treaties (DTAs), the treaty with Cyprus and the treaty with the UK, respectively.
Once the appropriate formalities have taken place in the reciprocal countries, these treaties are expected to come into force at the start of January 2020.
Ukraine: Cyprus Treaty
The key changes are:
A reduction in the withholding tax for … more
КАК ШВЕЙЦАРИЯ МОЖЕТ ПОМОЧЬ ЗАЩИТИТЬ АКТИВЫ В УСЛОВИЯХ РАСТУЩЕЙ ГЛОБАЛЬНОЙ НЕСТАБИЛЬНОСТИ
Швейцария - невероятно привлекательное государство для международных компаний и физических лиц с крупным частным капиталом, которые ищут экономической и политической стабильности.
Причины, по которым Швейцария выигрывает по сравнению с другими странами
Политическая, финансовая, социальна … more
Каковы возможности переезда физических лиц в Швейцарию, и каковы варианты их налоговой базы?
Многие жители других государств решают переехать в Швейцарию из-за её высокого качества жизни, здорового и активного образа жизни, и прекрасных условий и возможностей как для трудовой, так и для предпринимательской деятельности.
Благодаря своему местоположению в самом сердце Европы … more
When Might You Consider Using a Will Trust?
Will Trusts can be used to protect property and assets within an estate.
They can be particularly appropriate to provide gifts and inheritance for children from previous relationships and to leave assets to a vulnerable or disabled person.
What are Other Potential Uses of Will Trusts?
Will Trusts can also be used for the following: … more
Angola is one of the fastest growing economies in the world. Additional opportunities are available for companies established in Portugal due to implementation of double taxation provisions and the increased certainty that this brings.
One year after its approval, the Double Tax Agreement (DTA) between Portugal and Angola finally came into force on the 22nd of August 2019. … more
The Malta Financial Services Authority (MFSA) has published its Annual Report and Financial Statement for the year 2018. It presents an overview of the activities and work carried out by the MFSA, together with details about the industry’s performance and explains the Authority’s vision for the coming years.
Despite a challenging and highly competitive environment, in 2018, the Maltese financial … more
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
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
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
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
NEVIS AS A FINANCIAL CENTRE
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 … 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
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 Swiss 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 location.
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
TAXATION OF SWISS COMPANIES
Why Use Switzerland?
Switzerland is an attractive jurisdiction for the establishment of companies, as a location for individuals and for the provision of trust services. Advantages include:
Low rates of corporate tax for Swiss companies.
Lump Sum Tax for non-Swiss resident individuals.
A Swiss company can act as Trustee of a Trust formed under the Law … 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