• IN499 - Malta National Blockchain Strategy and Taskforce

    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

  • IN498 - UK Remittance Basis - It Needs to be Formally Claimed

    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

  • IN497 - Why Consider Cyprus as the Location for an Alternative Investment Fund?

    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

  • IN493 - The Isle of Man Shipping Registry - An Innovative Approach

    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

    Summary

    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

  • IN487 - Portugal - A Family and Business Friendly Jurisdiction

    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

  • IN486 - Portugal - New Golden Visa Investment Routes

    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

  • IN485 - New "60 Day" Tax Residency Rule for Individuals in Cyprus

    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

  • IN484 - IOM Mutual Funds - For International Family Portfolios

    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.

    Background

    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

  • IN483 - Access To Complementary Services From Nevis for Professional Firms In Other Jurisdictions

    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

  • IN482 - Benefits Offered By Nevis And The Use Of A Managed Trust Company

    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

  • IN475 - Moving Location - A Critical Time to Plan for Succession

    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

  • IN477 - Trusts Accounts Broken? – We Can Help Fix Them

    Introduction

    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

  • IN479 - Guernsey Register of Beneficial Ownership – A Unique Approach

    Background

    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

  • IN478 - Portugal – An Increasingly Attractive Location for Entrepreneurs

    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

  • IN474 - Providing Professional Firms in the BVI with Access to Complementary Services from Nevis

    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

  • IN473 - The Organisation of a Fund in Malta - The Benefits

    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

  • IN471 - Malta - Attractive Residence Programmes and Tax Benefits for Expatriates

    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

  • IN470 - Malta Holding Companies - Why Are They So Attractive?

    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

  • IN467 - Another Reason to Choose Cyprus - The Cyprus Non-Domicile Regime

    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.

    Background

    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

  • IN466 - Dixcart Business Centres: Serviced Offices Where and Why?

    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

  • IN464 - Fast Track Cyprus Citizenship by Investment and the Benefits it Offers

    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.

    *In one specific set of circumstances as detailed below in the financial criteria, the investment required is €2.0 million.

    A non-Cypriot citizen … more

  • IN463 - Isle of Man Financial Assistance Scheme - Enabling Entrepreneurs to Innovate on the Island

    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

  • IN462 - An Effective Guide: How to Reinstate a Cyprus Company

    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

  • IN461 - The Advantages and Relevant Procedures to Migrate a Company or Foundation to Guernsey

    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

  • IN459 - Relocating a Company to the UK? Why Consider the Dixcart Business Centre

    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

  • IN457 - Thinking of Flagging or Reflagging a Vessel? - Malta Could be the Answer

    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

  • IN456 - Reasons Why the Double Tax Agreement Between Cyprus and South Africa is so Attractive

    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

  • IN455 - Image Rights Registration and the Future Benefits This Can Offer

    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

  • IN453 - The Use of a Swiss Trustee: How and Why?

    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

  • IN452 - The Benefits of a Swiss Investment Holding Company

    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

  • IN451 - Why are Swiss Intellectual Property Holding Companies so Popular?

    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

  • 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

  • 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

  • JNE: Formation of Companies in Switzerland

    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

  • JNF: Formation of Companies in the UK

    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

  • 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

  • Nevis1b - Redomiciliation Of Bvi Companies To Nevis For Dissolution Purposes: A Cheaper And More Efficient Alternative

    Nevis and the British Virgin Islands (BVI) are leading international Caribbean financial centres, and both offer a good reputation and excellent standards.

    Potentially Reduced Costs

    Recent changes to legislation in the BVI mean that the cost of formally dissolving a BVI company in the BVI has increased considerably.

    In an ever competitive world where clients are cost sensitive, Nevis can … more

  • INGF1 - Guernsey Foundations

    Background

    On 25 July 2012 the States of Deliberation, Guernsey’s Parliament, approved the projet de loi The Foundations (Guernsey) Law, 2012 (the “Law”). The Law came into force on 7 January 2013.

    The Law is divided into three parts - the substantive law and two schedules. The first schedule deals with administrative matters, such as the establishment of foundations and their registration. The … more