The UK non-domicile regime remains a relatively attractive option with UK non-domiciles (“non-doms”) continuing to have the opportunity to enjoy significant tax advantages for a period of up to 15 years.
Major reforms regarding how UK non-domiciles are taxed were introduced in April 2017. As detailed in the Dixcart Article: UK Tax Residence - Planning Opportunities, Case Studies and How to Get … more
現行護照的認證複印件，註明姓名、照片、 … more
IN-Nevis Ec Cit Requirements (R) - Экономическая программа предоставления гражданства Сент-Китса и Невиса
Общие черты процесса
Главный заявитель должен заполнить четыре правительственных формуляра. (C1, C2, C3 и C4).
Заявители-иждивенцы должны заполнить только три формуляра (C1, C2 и C3).
Заполняется всеми заявителями и содержит личные данные каждого заявителя. (Вопрос C57 в формуляре касается дополнительной информации или сопровождающих документах, которые должны прилагаться к заявлен … more
The UK could be perceived to have one of the most punitive inheritance tax regimes in the world. Individuals pay a 40% rate on the value of their taxable estate above a tax free allowance of £325,000. In the case of a married couple this tax free allowance can be passed onto a surviving spouse, which means that, following their death, the estate will enjoy a £650,000 tax free allowance. … more
Please see Dixcart Article IN539, which details some additional changes in relation to foreign ownership of UK commercial real estate.
There have been a number of changes to the taxation of UK property in recent years. The majority of these changes have been focused on residential property and have not affected commercial property.
Ongoing reductions in UK corporate tax, now 19% and moving to … more
Many have asked “What are the implications caused by Brexit for the UK’s status as a premier jurisdiction for holding companies?”
In this Article we examine a number of the features that make a good holding company jurisdiction and consider the UK holding company in this context both pre and post Brexit.
Virtually all dividends received by a UK company, be they from the … more
On 8 September 2017, the second Finance Bill of 2017 was published. This confirmed that the previously announced policies, including amendments to the taxation of non-doms due to start on 6 April 2017, would be effective from that date.
In addition, further draft legislation, which will form part of a third Finance Bill, was published on 13 September 2017. This introduces new rules in relation … more
What is a Foundation?
A Foundation is an incorporated legal structure that can be used to hold assets. As a concept, it is neither a Trust nor a company; however it has features of both. During medieval times, a Foundation was originally founded as an asset holding entity under Civil Law in continental Europe, whereas the Common Law vehicle has been, and still is, the Trust. Foundations were … more
Malta introduced the Notional Interest Deduction Regime (NID) in October 2017. It comes into force at the start of the 2018 Maltese corporate tax year (1 January 2018).
What is NID?
NID is an innovative way for companies to reduce their tax liabilities. This option will be of greatest interest to companies with large equity balances.
NID allows companies to deduct a notional interest amount … more
IN500 - The Option of a Passport to Ease Travel whilst an Application for Alternative Citizenship is Underway
There are several attractive residence schemes whereby non-EU individuals can obtain citizenship and the right to a passport in an EU country.
Two of the most popular EU programmes are the Maltese Individual Investor Programme and the Portuguese Golden Visa Regime.
A St Kitts & Nevis passport could provide a relatively fast travel and if required, residence solution, whilst plans are being … more
Malta as a jurisdiction, with it generous and effective corporate tax system, is positioning itself as a leading Blockchain technology hub, with many state led initiatives currently underway.
Earlier this year the Maltese Government implemented a National Blockchain Strategy aimed at capitalising on the current opportunities for Malta to become a global Blockchain and Cryptocurrency front runner. … more
UK tax resident, non-domiciled, individuals who are taxed on the remittance basis, are not required to pay UK income tax and/or UK capital gains tax on foreign income and gains, as long as these are not remitted to the UK.
It is, however, crucial to ensure that this tax benefit is properly claimed. Failure to do so means that any planning undertaken by the individual might be ineffective and he/ … more
An 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 derivative … more
IN496 - What is a Guernsey Private Fund Structure and why are Family Offices Increasingly Using Them?
Why Guernsey For Private Fund Structures?
Guernsey is a leading domicile for funds, with more than 50 years of experience in the formation, administration and cross-border distribution of investment funds. It also offers a ‘lighter touch’ approach to Private Investment Structures (‘PS’), also known as Private Funds (‘PF’), which are ‘related party’ investment structures, particularly suitable … more
Advisers often need to guide clients on the most suitable jurisdiction to flag an owner’s vessel. Historically, advisers have preferred tried and tested jurisdictions, but this is starting to change, due to the increasing importance of jurisdiction perception, international transparency, time differences, different legal systems and growing costs associated with certain jurisdictions.
Criteria … more
IN489 - A New Residence Scheme in Malta and Favourable Changes to the Existing Residence and Visa Programme
The new ‘Key Employee Initiative’ programme in Malta allows for work/residence permits to be issued to prospective key (non-EU) employees within five working days from the date of the application.
Changes to the Malta ‘Residence and Visa Programme’ now allow the applicant and main dependents to apply for long-term residence in Malta after five years of residence.
In addition, parents … more
Since 2009 over 5,000 high net worth individuals and their families have made Portugal their home, attracted by the lifestyle, the Non-Habitual Resident tax regime and the Golden Visa residency programme.
In 2014 the Portuguese Government made Portugal more attractive to companies by reforming its Corporate Tax Code to meet international standards. Since then Portuguese companies have enjoyed an … more
15,000 high net worth individuals and their families have moved to Portugal since 2009.
Portugal appears to be the place to be, with beautiful scenery and cities like Lisbon, Porto and Funchal to explore. Families who have moved to Portugal are attracted by the personal tax programme: the Non-Habitual Resident Programme. Non-EU individuals also have the option to move to Portugal by applying for … more
In July 2017, the Cyprus Parliament voted for an amendment to the current criteria used to determine Cyprus tax residency. In addition to the 183 day rule, a second test is being introduced in relation to an individual’s tax position in Cyprus.
The current “183 day rule” applies to individuals who have physically resided in Cyprus for more than 183 days during one calendar year.
In addition to … more
Wealth preservation, return and management are core objectives for the majority of successful family office situations. The ability to consolidate resources and communicate clearly on performance can provide a family with huge benefits and save time and resources.
A mutual fund is an investment vehicle consisting of a pool of funds which can be collected from within the family for the purpose of … more
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 finding ways to leave the Economic Adjustment Programme, agreed with the European Commission for the period 2010-2014 (the bailout programme).
In the past Portugal discovered … 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’s needs as … 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
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
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
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
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
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
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
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