Malta – An Attractive Destination for IP Holding Companies

Malta is one of the most attractive destinations for establishing holding companies dedicated to managing intellectual property (IP), thanks to its combination of favourable tax benefits, a strong legal framework, a network of over 70 Double Taxation Agreements (DTAs) and direct access to the European single market. In 2025, setting up a company in Malta to manage IP is a smart choice, as the country’s tax system offers significant incentives that allow for tax optimisation, facilitate profit repatriation, and protect intangible assets effectively.

The Maltese Corporate Tax Regime

Malta’s full imputation tax regime is a key draw for IP businesses, offering a tax refund mechanism to non-resident shareholders that effectively reduces the  corporate tax rate to 5%. This is combined with the absence of any withholding tax on dividends, royalties, or interest paid to non-residents.

Benefits in Malta For IP Holding Companies

These factors make Malta one of the most tax-efficient jurisdictions for holding intellectual property, benefiting both local and international investors. Royalties from active licensing activities, which are initially taxed at 35%, can be reduced to just 5% under this regime in case of multiple royalties’ streams. Effective taxation would be 10% in case of only one royalties’ stream.

Another significant advantage is Malta’s exemption from taxation on royalties derived from patents or copyrights, whether developed in Malta or abroad. Additionally, profits from these royalties can be distributed as tax-free dividends to shareholders, optimising returns on investment.

When the IP is transferred within a group or from an individual to a company, it can be revalued at fair market value (FMV) for tax purposes. This increases the asset’s base for amortisation, reducing taxable income. Malta allows companies to amortise the stepped-up value of IP over a minimum period of three years, leading to significant tax deductions. With a properly structured transfer, the capital gain arising from the step-up may qualify for participation exemption (in certain cases) or be taxed at the corporate rate of 35%.

UE Membership

Furthermore, the EU Interest and Royalties Directive allows for tax-free royalty payments between associated companies within the EU, making it even easier to repatriate profits. Malta,  as a member of the European Union, is fully aligned with European regulations, allowing it to offer excellent protection for intellectual property under European legal frameworks. Thanks to its EU membership, IP rights such as trademarks, patents, and designs can be registered both through the national system and the European Union Intellectual Property Office (EUIPO). This provides access to a market of over 450 million people and ensures strong protection across the region. On a global scale, Malta is also a signatory of key international treaties such as the Paris Convention, the Berne Convention, and the TRIPS Agreement (Agreement on Trade-Related Aspects of Intellectual Property Rights), ensuring that IP assets are strongly protected worldwide.

Registration

The process of registering and managing IP in Malta is relatively straightforward and affordable compared to other European countries. Registration fees are lower, and the annual administrative costs of maintaining a holding company in Malta are also competitive, enabling businesses to keep their operational costs low and achieve higher profitability. For IP assets, trademarks can be registered through the Malta Trade Department or the EUIPO, while patents are handled through the Malta Intellectual Property Office or the European Patent Office (EPO). These registration processes allow companies to secure ownership and control over their intangible assets, taking advantage of a stable and reliable legal environment.

Additional Information

For additional information, please speak to Jonathan Vassallo at the Dixcart office in Malta: advice.malta@dixcart.com or get in touch with your usual Dixcart contact.

Our team at the Dixcart office in Malta can assist you with the establishment of an IP Holding Company in Malta and manage all the relative accounting, compliance and legal-related sides of the business.

Register of Overseas Entities and Its Impact on Property Ownership

Register of Overseas Entities Background

The Register of Overseas Entities, effective from 1 August 2022 under the Economic Crime (Transparency and Enforcement) Act 2022, requires overseas companies and other non-human entities owning property in the UK to register with Companies House and disclose their beneficial owners or managing officers.

Most of the information given to Companies House about overseas entities, beneficial owners and managing officers, will be publicly available on the Register of Overseas Entities. This is intended to increase transparency, allowing law enforcement agencies to investigate suspicious wealth more effectively. 

Changes to Trust Data Access on the Register of Overseas Entities

Over the coming year, there will be changes to the public visibility of data held on the Register of Overseas Entities:

Protection of Trust Data (from 28 February 2025)

Most data relating to Trusts must be provided to the authorities but historically, it has not been publicly visible. However, this will become available on request (see below).

From 28 February 2025, you can apply to protect your Trust data from public availability if you meet the necessary criteria. You can apply to protect your details (or anyone that lives with you) if you are at risk of harm or intimidation if your information is available to the public. You cannot request protection just because you wish to keep information confidential and there must be a genuine risk of violence or intimidation.

Eligible Trust members who may apply for protection include beneficiaries, settlors, grantors, and interested parties.

You can also apply if you have the authority to act on behalf of a Trust member who is a minor (aged 17 and under) or lacks capacity as defined in Section 2 of the Mental Capacity Act 2005 You will need to provide evidence in this case.

Read more about the criteria and how to apply for protection on GOV.​UK and you can also request a paper form to apply for protection.

You’ll need to pay £100 per application. This will be refunded if your application is rejected.

Public Access to Trust Data (from 31 August 2025)

Trust data on the Register of Overseas Entities will be available on request from anyone that applies to the Registrar, this provision comes into force 31 August 2025.

  • Following an application, Companies House may share information that is held on the register with third parties.
  • Requests must include applicant details and purpose – this must contain applicant’s name, contact details, job title/details, name of the overseas entity and OE number and/or name of the trust.
  • A legitimate interest test applies for minors or multiple Trusts—only granted for investigations into money laundering, terrorist financing, tax evasion, or sanctions avoidance.
  • Companies House may impose restrictions on disclosed information – such as restricting the use of the information or further disclosures.
  • A request may be refused on a number of grounds, including where the disclosure may prejudice an ongoing criminal investigation, it may adversely affect national security or where the Trust is a pension scheme.

Keeping Register Information Updated

  • Entities must ensure their Trust data is accurate and update it in their annual statement if necessary.

Home Address

You can also apply to Companies House to remove your home address (usual residential address) if it is shown on the register. In order to remove your home address, you need to offer a replacement principal office or service address.

Additional information

If you require any addition information regarding or assistance with a registration or filing an update statement, please contact the Dixcart office in the UK: advice.uk@dixcart.com.

More information can also be found within our article: UK Register of Overseas Entities and Update Statements.

Cyprus company in investment

Using a Cyprus Company for Investment in the Stock Market

Introduction

An increasing number of individuals worldwide now hold investment portfolios, yet many overlook the present and future tax implications of their investments. In today’s dynamic global economy, safeguarding your assets in a stable, advantageous jurisdiction has become more important than ever.

Why use a Cyprus Company?

If you are seeking an optimal jurisdiction for structuring your investments, Cyprus offers a compelling solution. With a straightforward, stable, and proven fiscal framework, Cyprus provides a highly attractive tax regime for managing portfolio investments, making it an ideal location for establishing a portfolio holding company.

In a climate of heightened transparency and the negative associations tied to traditional offshore jurisdictions, investors increasingly prefer structuring their portfolios through EU-based entities. Cyprus stands out as a prime choice, offering numerous advantages:

  • EU and Eurozone Membership: Cyprus benefits from the economic stability and regulatory alignment of the EU and Eurozone.
  • Attractive Tax Regime: One of the most competitive tax systems in Europe.
  • Established Financial Centre: Cyprus boasts a reputable financial infrastructure with a long-standing history.
  • Qualified Professionals: Access to a vast pool of experienced professionals and business service providers.
  • International Recognition: Cyprus is a whitelisted jurisdiction acknowledged by global regulatory bodies.
  • Cost Efficiency: Lower maintenance costs compared to other EU jurisdictions.
  • Strategic Location: Situated at the crossroads of Europe, Asia, and Africa.

A further advantage of using a Cyprus company for portfolio holdings is the flexibility to open bank accounts, engage brokers, and work with investment managers from any jurisdiction. Many individuals successfully utilise Swiss and other EU banks for their Cyprus companies.

How are Portfolio Profits Taxed in Cyprus?

  • Dividend Income: Dividend income received by a Cyprus company from financial instruments is generally tax-exempt.
  • Capital Gains and Trading Profits: Profits from the disposal of shares and other qualifying financial instruments are generally exempt from Cyprus taxation.
  • Interest Income:
    • Active Interest: Interest earned from active sources is taxed at a rate of 12.5% on net profits.
    • Passive Interest: Interest from passive sources is not subject to income tax but instead taxed under the Special Defence Contribution (SDC) tax at a rate of 17% on the gross amount.
  • Withholding Tax:
    • Inward Receipts: Cyprus benefits from over 60 double tax treaties as well as the EU Parent-Subsidiary Directive. As a result, taxes withheld in the country of origin are often applied at a very favourable rate.
    • Outgoing Payments: Provided that the recipient (whether an individual or a corporate entity) is tax resident in an OECD-compliant jurisdiction, there are generally no withholding taxes (WHT) on distributions from Cyprus to shareholders.

All companies that wish to make the most of the above benefits must be considered tax resident in Cyprus. In order to be considered tax resident a company must have sufficient economic substance in Cyprus.

How Can Dixcart Help You?

With over 50 years of experience in the sector, we have a wealth of knowledge in assisting individuals, families and corporates establish fully bespoke, compliant solutions. Our highly qualified team offer in-depth expert knowledge of the local regulatory framework, supported by our international network of offices, to help us find the ideal solution for you.

We provide a full suite of support services including incorporation, accounting, company secretarial, compliance, and other day-to-day support.

We are also not affiliated with any single bank, investment manager, or fund adviser. Instead, we maintain a diverse network of connections, enabling us to match you with the professional best suited to your unique requirements. This approach ensures impartiality and allows for the selection of the most appropriate third-party support, free from conflicts of interest.

If you are interested in establishing a holding company to manage your investment portfolio, please contact us. We would be delighted to answer any questions you may have and assist in creating the optimal structure for your needs. please contact us advice.cyprus@dixcart.com for more information.

The data contained within this Information Note is for general information only. No responsibility can be accepted for inaccuracies. Readers are also advised that the law and practice may change from time to time.

How to Establish Your Business in Portugal

Portugal has emerged as an ideal destination for entrepreneurs and businesses seeking a stable, business-friendly environment within the European Union. With its strategic location, attractive tax regime, and vibrant economy, Portugal offers numerous opportunities for growth. If you are starting from scratch or considering re-domiciliation, this guide will walk you through the essential steps to establish your business in Portugal.  

1. Incorporation: Starting Fresh or Redomiciling

You have two primary options for establishing your business in Portugal:

  • Incorporation: This involves creating a new Portuguese company, adhering to all local legal and regulatory requirements. It is the most common approach for businesses entering the Portuguese market.  
  • Re-domiciliation: This process involves transferring an existing company’s legal domicile from another jurisdiction (e.g. France) to Portugal. This can help companies benefit from Portugal’s tax advantages and EU membership. However, it requires careful legal and tax planning to ensure compliance with both the original and new jurisdiction.

2. The Company Incorporation Process

The process of incorporating a company in Portugal generally involves these steps:

  • Choosing a Company Structure: The most common types are:
    • Sociedade por Quotas (Lda.): A limited liability company, suitable for small to medium-sized enterprises.
    • Sociedade Anónima (SA): A public limited company, typically used for larger businesses.
    • Read here for more information on company structures in Portugal.
  • Obtaining a Company Name Approval: You must register your chosen company name with the National Registry of Legal Persons (RNPC – Registo Nacional de Pessoas Colectivas). Other than confirming uniqueness, it ensures the company’s name complies with Portuguese legal requirements.
  • Drafting the Company Statutes: These documents outline the company’s structure, objectives, and operational procedures – essential for establishing a clear and legally sound foundation for the company’s operations, governance, and roles and responsibilities of shareholder and directors. This serves as the company’s internal governance guide and is required for the registration of the company at the commercial registry.
  • Obtaining a Tax Identification Number: The Portuguese tax system necessitates two types of tax identification numbers – namely:
    • NIPC (Número de Identificação de Pessoa Colectiva), the corporate tax number, is automatically assigned upon approval of the company’s name. This enables the company to fulfil tax obligations, engage in legal and financial transactions (such as opening bank accounts), and operate legally within Portugal.
    • NIF (Número de Identificação Fiscal), individual’s tax number, for individuals associated with the company, including directors and shareholders. This NIF is for their individual tax liabilities and any financial dealings related to the company.
  • Opening a Bank Account: Essential for depositing the company’s share capital and managing financial transactions. Although it is not a prerequisite to have a Portuguese bank account, a bank account in Portugal is beneficial to transact with the Portuguese tax authorities (e.g. receive refunds from the tax authorities, for payment of employment social security amounts, etc.).
  • Registering the Company at the Commercial Registry: This formalises the company’s existence and grants the company its legal personality. A registration fee is payable.
  • Registering the Company with Social Security: Portuguese companies are required to register for social security (whether they have employees or not) – for which it will receive a unique social security registration number. This ensures, among others, compliance with labour laws.
  • Obtaining Necessary Licenses and Permits: Companies may be required to obtain specific licenses or permits to operate in Portugal or the EU, depending on the scope of business activities and sector-specific requirements.

3. Shareholder Registry of Beneficial Owners and Public Access

Company ownership information in Portugal is generally public. The Commercial Registry discloses shareholder details, for limited liability companies. However, the Central Register of Beneficial Owners (RCBE) is needed to identify UBOs (Ultimate Beneficial Owners) with significant ownership (over 25% ownership or control), although searches are by company name only. Listed companies also report ownership changes through the CMVM (Comissão do Mercado de Valores Mobiliários) – the Portuguese Securities Market Commission. Despite these registries, identifying the true UBO can be difficult with complex structures.

4. Tax Rates and Considerations

  • Portugal’s tax regime is a significant draw for businesses. Key aspects include:  
    • Portugal Mainland: The standard rate is 20%, with reduced rates for small andmedium-sized enterprises (SMEs) of 16% on the first €50,000 of net taxable income.
    • Autonomous Region of Madeira: The standard rate is 14.7%, with reduced rates for small and medium-sized enterprises (SMEs) of 11.9% on the first €50,000 of net taxable income.
      • If the company is involved in international activities, a 5% rate may apply through the Madeira International Business Centre (MIBC) – see here.
    • Value Added Tax (IVA): Standard rates are 23% in mainland Portugal, with reduced rates for certain goods and services. Reduced rates apply in Madeira and the Azores.
    • Non-Habitual Resident (NHR) Regime: Offers significant tax benefits for individuals (such as employees, directors, and shareholders tax resident in Portugal who qualify), including potential tax exemptions on foreign-sourced income. See here for more information.

5. Obligations to Shareholders and Directors

  • Shareholders: Are entitled to dividends and have voting rights. They are also liable for the company’s debts up to their share capital.  
  • Directors: Are responsible for managing the company’s affairs, complying with legal obligations, and acting in the best interests of the company. They have fiduciary duties and can be held liable for breaches of these duties. Directors are required to act with reasonable skill and diligence.

6. Opening a Bank Account

Without a bank account, a corporate entity may have no use. Portuguese banks and authorities have strict KYC (‘Know-Your-Client’) requirements to prevent money laundering and terrorist financing. Expect to provide detailed information about your company’s ownership structure, business activities, and shareholder’s source of funds.

The following may be required as a starting point:

  • Company incorporation documents as detailed above
  • NIPC (company’s registration and tax number) of the company
  • Identification documents for directors and shareholders
  • Proof of address (the company’s individual shareholders)
  • Source of funds and wealth of shareholders and/or UBO

Although bank accounts may be opened remotely, it may be faster and more convenient to open in person.

7. Ensuring Company Substance

Demonstrating economic substance is critical for tax compliance in Portugal. Companies must maintain genuine economic activities and a physical presence within the country. Furthermore, to qualify for the 5% corporate income tax rate in Madeira’s International Business Centre, companies must meet specific substance requirements.

8. Reasons to Incorporate in Portugal

Lastly, various businesses have recently incorporated or redomiciled to Portugal. The reasons are vast and different, many of which have decided based on the following factors:

  • EU Membership: Access to the European single market to conduct business.
  • Stable Political and Economic Environment: Provides a secure base for business operations.
  • Strategic Location: A gateway to Europe, Africa, and South America.
  • Network of Double Taxation Agreements: Portugal has almost 80 double taxation agreements – some of which are unique like the agreement between Portugal and Angola. Click here for more information on double taxation agreements.
  • Skilled Workforce: A growing pool of talent that can speak several languages, including English.
  • Quality of Life: A desirable location for professionals and families.  
  • Growing Tech Hub: Lisbon and other cities are attracting tech companies and startups. Read here for more information.

Visa program: Various visa programs are available, including the golden visa. Refer here for more details.

Conclusion

Establishing a business in Portugal requires careful planning and adherence to local requirements. However, the potential rewards are significant. By understanding the incorporation process, tax implications, and regulatory obligations, you can successfully launch and grow your business in this dynamic and promising market. It is highly recommended to seek professional advice to navigate the complexities of Portugal which may be different to the jurisdiction you are accustomed to.

Please contact advice.portugal@dixcart.com for a free initial consultation.

Swiss company

The Advantages of Using a Swiss Company to Hold Investments Owned by Turkish Residents or Companies

Introduction

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 11.9% and 14% rather than the relevant corporate tax rate in Turkey of 25%, or rather than the individual income rate of 40% (marginal tax rate).

b) Reducing the information that needs to be provided to Turkey under CRS Regulations.

c) Turkey has a double taxation treaty with Switzerland, the tax clauses of which came into force on 1 January 2013.

Turkish CFC Rules and Swiss Corporate Tax

As described above Swiss companies present an interesting opportunity as their corporate tax rates vary between 11.9% and 14% (depending on which Swiss canton they are located in). This is helpful because Under Turkish CFC rules, undistributed income of foreign subsidiaries should not be payable in Turkey when the foreign company’s corporate tax is above 10%.

Investment Currency Fluctuations

The fluctuations of the Turkish Lira against major currencies can trigger taxable foreign exchange gains, when held by Turkish individuals and corporate taxpayers. Investment currency fluctuations are taxed in Turkey, even when not realised. A Swiss company is not taxed on investment currency fluctuations, as long as the gains are not realised.

Equities are registered at their acquisition value in Swiss financial statements, providing they are not sold and a profit is realised.

Withholding Tax

Should the Swiss company distribute dividends to a Turkish shareholder, the effective withholding tax rates are 15% for an individual shareholder and 5% for a corporate shareholder.

A tax credit is available in Turkey against Turkish income tax.

Exchange of Information – Swiss Portfolio Investments

The exchange of information between Switzerland and Turkey will come into force in January 2021, with the first exchange of data in 2022, covering the reporting period from 1st of January to 31st of December 2021.

The information exchanged will vary subject to the CRS classification of the Swiss company. Depending on the services provided to the Swiss company and on its activity in Switzerland, Swiss companies and their UBOs are treated to varying degrees of transparency under CRS rules.

Additional Information

#If you would like additional information regarding the use of a Swiss company to hold portfolio investments, owned by Turkish residents and/or companies, please contact Christine Breitler or Thierry Groppi at the Dixcart Switzerland Office:  advice.switzerland@dixcart.com

Cyprus as a Gateway for Indian Cross Border Transactions

Introduction

Cyprus and India have long maintained close and friendly bilateral relations, progressively strengthening their economic, scientific, and technical cooperation.

On 18 November 2016, Cyprus and India signed a revised agreement for the avoidance of double taxation and prevention of fiscal evasion concerning taxes on income (Double Taxation Treaty “DTT”), replacing the previous DTT established in 1994.

With minor adjustments, the DTT agreement aligns closely with the OECD Model Convention for the Avoidance of Double Taxation on Income and on Capital.

Advantages of the Cyprus Corporate Tax Regime

Provided a company meets the economic substance requirements and is considered a tax resident in Cyprus then they will enjoy the favourable corporate tax regime on offer. Some of the many benefits a Cyprus company can enjoy include:

  • Corporate tax rate of 12.5%, one of the lowest in Europe. Thiscan be lowered to 2.5% through the use of the Notional Interest Deduction (NID). Please see our detailed article on the NID here.
  • Inbound dividends are not taxable (subject to conditions), and there are also no capital gains tax on the sale of securities and disposal of shares.
  • The revised treaty assigns taxing rights to the source country for capital gains from the alienation of shares. Gains from shares acquired before 1 April 2017 are taxable only in the seller’s country of residence, while gains from shares acquired on or after 1 April 2017 may be taxed by the source country.
  • There is no withholding tax on dividends, interest, and royalties paid from Cyprus, provided the royalty rights were exercised outside Cyprus.
  • The following are the maximum withholding tax (WHT) rates on inbound payments from Cyprus to India under the treaty (subject to possible lower rates or exemptions under domestic law provisions):
    • Dividends: 10%
    • Interest: 0%*/10%
      • NIL, if the beneficial owner of the interest is the Government, a political subdivision, a local authority of the other Contracting State, or specified financial institutions such as the Reserve Bank of India.
    • Royalties: 10%
      • A WHT rate of 10% also applies for payments of a technical, managerial, or consulting nature.
  • Cyprus has a vast network of Double Tax Treaties (DTTs) aimed at preventing double taxation.

Cyprus Holding Company

As a result of the above, Cyprus companies can be effective holding entities for Indian companies involved in international cross-border transactions. A Cyprus company can own 100% of an Indian company engaging in various investments. From a Cyprus perspective, no participation or holding requirements are necessary to obtain tax benefits. Incoming dividends from India are exempt from Cyprus corporation tax and will also be exempt from Special Defence Contribution (SDC) at a rate of 17%, provided that:

  • The Indian company paying the dividend engages directly or indirectly in more than 50% of activities generating non-investment income, or
  • The Indian tax burden on the income of the paying company is not significantly lower than the Cyprus tax burden (defined as less than 50% of Cyprus’s corporate tax rate, i.e., lower than 6.25%).

Additionally, a Cyprus entity can be used as an intermediary for channelling foreign direct investments (FDIs) into India or other countries or can be used to accumulate group profits which can be reinvested without triggering additional tax liabilities.

How Can Dixcart help?

For over 50 years, Dixcart has been a trusted partner, assisting clients with international structuring, company incorporation, and management. Our extensive local expertise and dedicated team have established us as leaders in the field.

We are committed to guiding you through every stage of the process, from setting up and registering a Cyprus company to providing management, accounting services, and fully serviced office space. Dixcart Cyprus is your comprehensive solution for incorporating a Cyprus entity and maximising the advantages it offers.

Our team will support you in gathering and organising all necessary documents while ensuring full compliance with local and international regulations. We will liaise directly with governing bodies on your behalf to streamline the process and safeguard regulatory adherence.

If you would like to explore the benefits of establishing a Cyprus company or have any questions about our services, please contact Dixcart Cyprus for further information at: advice.cyprus@dixcart.com.

Effective First Steps Towards Establishing a Company in Switzerland

The jurisdiction of Switzerland offers numerous advantages.

Based in the heart of Europe, it has a long tradition as an internationally respected finance and banking hub. It is renowned as a centre for private wealth.

The Challenge

Switzerland is considered a top level jurisdiction, in terms of international standards.

This has an impact on the establishment and management of companies, as much as it affects other areas of life in Switzerland.

  • We are often asked by clients, if there might be an alternative, a first step towards setting up a company in Switzerland.

The answer is yes.

The Solutions

Non-Swiss companies often need Swiss based employees, particularly when they are expanding into the Swiss market for the first time. Quite often this is to carry out a business development role, but there are many other situations when a Swiss employee or employees are needed.

Frequently, a local representative is needed in Switzerland, but it might be a little early to establish a Swiss company.

Two Options

There are two options:

  • The non-Swiss company directly hires the employees and Dixcart Switzerland represents the company;

OR

  • Dixcart Switzerland opens a branch, in Switzerland, for the non-Swiss company and runs the branch. This offers the advantage of providing more substance in Switzerland.

What Advice and Support can Dixcart in Switzerland Provide?

We can provide advice as to the best solution to meet the particular circumstances and can help generate an effective business plan. In addition we can provide day to day administrative services to ensure the smooth running of this first step into the Swiss market.

Dixcart Switzerland services include:

  • Bookkeeping
  • Business plans
  • Payroll
  • Preparation of annual accounts
  • Preparation of annual returns
  • Swiss insurance expertise
  • Swiss social security expertise
  • Value added tax reporting and payment (VAT)

Payroll Services

Specific services in relation to the payroll function include:

  • Salary calculations
  • Social security calculations and payments
  • Payroll tax calculations and payments

Serviced Offices

Serviced offices are available in the same premises as Dixcart Switzerland. Desks with internet connection, are used by serviced office clients, with telephone lines and secretarial support available, if required.

What Additional Support is Available – When a Company is Established in Switzerland?

If the business in Switzerland expands and it becomes viable and beneficial to establish a Swiss company, Dixcart Switzerland can assist with:

  • Accounting

Working with clients at every stage of their business life cycle, we are able to set up the complete internal finance function, if required. 

  • Management Accounts

Dixcart frequently provide management accounts for a large variety of different companies. These can be generated monthly, quarterly or annually, to help make running the company as efficient as possible.

  • Provision of Directors

A number of the companies that Dixcart manage have a Dixcart professional on their Board of Directors. The technical professional expertise, impartial perspective and extensive experience at director level  that a Dixcart director can provide, is often of substantial benefit.

Additional Information

If you would like additional information regarding the first steps towards setting up a company in Switzerland, please contact Christine Breitler at the Dixcart office in Switzerland: advice.switzerland@dixcart.com.

Redomiciling Your Company to the Isle of Man

Global mobility and the portability of Corporate Structures has become increasingly important to Clients and their Advisers, who often move corporate entities from one jurisdiction to another. A prerequisite to Redomiciliation is that both the jurisdiction of incorporation, and the new jurisdiction where the Company will continue, both make provision for this in their Company Law. Like many international financial centres, the Isle of Man’s Companies Acts enable Redomiciliation.

What Effect Does Redomiciliation Have on the Company?

The continuance of a Foreign Company in the Isle of Man does not create a new legal entity or prejudice or affect the continuity of that company, its assets, liabilities, and obligations.

If the Company undertakes a licensable activity, such as Banking, Insurance, E-gaming etc. it will need to contact the corresponding Regulatory Authority or Licensing Body to ensure that there are no issues.

Consideration must also be given to the name of the continuing company, ensuring that it complies with the relevant Companies Acts and any restricted words and phrases where prior permission will need to be sought, as detailed by the guidance provided by the Isle of Man Companies Registry.

Why are Companies Redomiciled?

Redomiciliation is carried out for a wide variety of reasons, which can include:

  • The facilitation of operational efficiencies.
  • To undertake restructuring.
  • Moving to a reputable jurisdiction to provide comfort to investors, lenders, and banking institutions.
  • To benefit from political and economic stability.
  • To change Trust & Corporate Service Provider for better service.

You can read more about the benefits of Isle of Man Companies here.

Why Redomicile Your Company to the Isle of Man?

The Isle of Man is a leading international financial hub that is globally recognised as well regulated and a reputable jurisdiction to do business from.

Those Foreign companies seeking to Redomicile to the Isle of Man have a choice of Companies Acts to register under – the more traditional Companies Act 1931, or the streamlined Companies Act 2006 – which provides a large degree of flexibility.

Once Redomiciled, the company can benefit from the Island’s tax regime, boasting rates such as 0% Corporate Tax, 0% Capital Gains Tax and no Withholding Tax on Dividends.

The Island is politically neutral and business friendly, meaning that the legislative environment is reliable and enduring, particularly as the Isle of Man makes its own laws. In addition, whilst the Case Law of England & Wales is persuasive, it is not binding.

The Isle of Man’s credit strength, diverse economy and ability to comply with global tax standards are all reflected in its Moody’s Credit Rating of Aa3 Stable, per their 01 November 2023 assessment.

How Can Dixcart Assist with Your Redomiciliation?

Dixcart Management (IOM) Limited is Licensed and Regulated in the Isle of Man to deliver Trust & Corporate services and has been in operation since 1989.

Our expert team of qualified professionals has been developed to administer clients’ Isle of Man Companies, Trusts and Foundations to an exceptional standard, delivering a tailored and dedicated service.

You can read more about how our Isle of Man office can support your Corporate Structuring here.

Contact Us

If you are considering Redomiciling your company to the Isle of Man or changing service provider, get in touch with Paul Harvey at Dixcart: advice.iom@dixcart.com

Dixcart Management (IOM) Limited is Licensed by the Isle of Man Financial Service Authority

Exciting Changes to the Cyprus Startup Visa Scheme and New Opportunities for Global Entrepreneurs

Introduction

At the end of 2024 a number of revisions to the existing Cyprus Startup Visa Scheme were approved. These changes make an already very attractive scheme more appealing and accessible.

Overview of the Scheme

The Cyprus Startup Visa Scheme allows talented entrepreneurs from non-EU and non-EEA countries, whether individuals or a team, to enter, reside and work in Cyprus while establishing, operating, or growing a high-potential Startup. The aim of the scheme is to create new job opportunities in Cyprus, promote innovation and research, grow the business ecosystem and consequently the overall economic development of the country.

For the purposes of the Scheme, Innovative Startups are defined as unlisted small enterprises registered within the last 5 years, with no profit distribution and have not been formed through a merger. The enterprise should develop or offer new products, services, or processes that create or disrupt markets. Such innovations are based on new technologies, should adapt existing technologies, and/or employ new business models.

Beneficiaries of the Scheme are categorised under either the ‘Individual Startup visa scheme’ or under the ‘Team Startup visa scheme’.  A team is considered as “a maximum of 5 individuals consisting of non-EU country nationals”. The Team should consist solely of the founders of an innovative Startup or of at least one founder and other senior executives. In both the Individual and the Team Startup visa scheme at least 25% of the company’s shares should be owned by one or more member(s) of the applicant or team of applicants.

What has Changed?

The revisions to the Cyprus Startup Visa Scheme include:

  • An extension to the residence permit offered to successful applicants from 2 to 3 years, with a possibility of 2-year renewals, instead of the original renewal for 1 year;
  • A reduction to the required percentage of equity third country applicants must have in the Cypriot company from 50% to 25%. It is noted that a start-up group applying for this specific visa may consist of up to five founders (or one founder and additional executive members), and must have a minimum of €20,000 capital or €10,000 if the founders are less than two;
  • The ability to increase the number of third country nationals employed from 30% to 50% of the company’s entire staff, with the option of hiring additional foreign personnel if the start-up investment in Cyprus is equal to, or exceeds, €150,000;
  • The implementation of different evaluation criteria for start-ups that have sales revenues of at least €1,000,000, and whose research and development expenditure amounts to at least 10% of the total operating expenses for one of the past 3 years.

While the updated programme offers greater flexibility to foreign entrepreneurs and investors, it also establishes more distinct and objective conditions for the renewal of the start-up visa after the initial 3-year period. Specifically, start-ups wishing to renew their relevant visas will be required to demonstrate either a minimum increase of 15% in their revenues or investments of at least €150,000 during the period of their operation in Cyprus. Additionally, the companies applying for a renewal visa will be expected to have either created at least 3 new jobs in Cyprus, or participated in a local innovation support scheme, or launched at least one product or service.

Tax Benefits

With an ever-expanding double tax treaty network of approximately 70 countries across the globe, Cyprus offers a number of tax benefits to start-ups and foreign investors of such start-ups, such as:

  • A non-Cypriot individual relocating to Cyprus to set-up their startup is exempt from tax on dividends, capital gains and most types of interest income, though they will still be subject to income tax on any income earned as a salary from their employment in Cyprus.
  • Investors in innovative start-up companies (which have been certified as such by the Ministry of Finance in Cyprus) can enjoy up to 50% tax exemption on their annual taxable income in Cyprus.
  • Corporate tax on net profits of Cypriot companies is currently set at 12.5%. Technology companies producing Intellectual Property can apply for an 80% tax exemption, reducing the corporate tax rate to an effective 2.5%.
  • Capital gains arising from the disposal of the qualifying IP are fully exempt from tax. Any gains earned by the entrepreneur from the disposal of his/her shares in a Cypriot tax resident company are generally exempt from tax in Cyprus.
  • Cyprus tax resident companies may carry forward tax losses incurred during a tax year over the following 5 tax years to offset future taxable profits, allowing startups, which are commonly loss making in their early stages, to benefit in the future.
  • Upon the introduction of new equity, a Cyprus tax resident company is entitled to claim a notional interest deduction (NID) as a tax-deductible expense. The deduction is available on an annual basis and may reach up to 80% of the taxable profit generated from the new equity. Depending on the level of capitalisation, a startup company may reduce its effective tax rate to as low as 2.5%.
  • Profits from disposals of corporate ‘titles’ are tax exempted from corporate income tax. However, capital gains on immovable property situated in Cyprus (on non-quoted shares directly or indirectly holding such Cyprus-situated immovable property) are taxed.
  • Special defence contribution is imposed only on non-exempt dividend income, ‘passive’ interest income, and rental income earned by Cypriot tax resident companies and Cypriot permanent establishments of non-Cyprus tax resident companies.

How can Dixcart Cyprus Help?

With over 50 years of expertise in the industry, we bring a deep understanding of supporting individuals, families, and businesses. Our teams combine extensive knowledge of the local regulatory framework with the global reach, resources and expertise of our international group, ensuring we deliver tailored solutions that perfectly meet your needs.

At Dixcart, we recognise that every client is unique, and we pride ourselves on offering personalised services. By working closely with you, we gain an in-depth understanding of your specific requirements, enabling us to provide bespoke solutions, recommend the most suitable structures, and support you every step of the way.

Our comprehensive range of services include company incorporation, management and accounting services, company secretarial support, and even providing a fully serviced office for your Cypriot company.

If you are considering how Cyprus can play a role in managing your wealth or business needs, we would be delighted to discuss your options. Please do not hesitate to contact us at advice.cyprus@dixcart.com.

2024 Overview: Key Articles and Insights from Dixcart Switzerland

Introduction

As we approach the end of 2024, we reflect on the key articles shared by our Switzerland office this year. Below are concise summaries of Dixcart Switzerland’s 2024 articles, offering practical guidance on Swiss residency, trusts, and business opportunities.

1. Swiss Regulation: 2023 Overview and What to Expect in 2024
Key regulatory updates for 2024 include VAT rate increases, a 15% minimum corporate tax for multinationals, and the removal of import duties to boost economic competitiveness. Reflections on 2023 cover the Swiss-UK financial treaty, updates to the Federal Act on Data Protection, corporate law reforms, and enhanced anti-money laundering measures.

2. Setting Up a Business in Switzerland
Comprehensive guidance on starting a business in Switzerland, including legal structures such as sole proprietorships, partnerships, and limited liability companies. Highlights include essential steps for registration, tax implications, and adherence to employment regulations.

3. Dixcart Gains Regulated Trustee Status in Switzerland – Understanding the Significance
Dixcart Trustees Switzerland (SA) attained regulated trustee status from FINMA, aligning with Swiss structural and business-conduct standards. Key advantages of Swiss trusts include confidentiality, tax efficiency, and enhanced wealth preservation opportunities.

4. The Role of a Swiss Trustee: Exploring How and Why They are Beneficial
Swiss Trustees play a pivotal role in estate planning, wealth management, and asset protection. Switzerland’s central location, leading banking infrastructure, and strong commitment to confidentiality make it an ideal jurisdiction for trustee services.

5. How to Become Swiss Resident by Working in Switzerland
Switzerland provides several routes to residency through work, including employment with a Swiss company, forming a business, or investing in one. EU/EFTA nationals benefit from easier processes, while non-EU/EFTA nationals have stricter requirements. Taxation differs by canton, and contributions through business activities often benefit local economies.

6. Introduction of Swiss Trusts
Swiss Trusts and Private Trust Companies (PTCs) offer secure asset protection, confidentiality, and succession planning options. Trusts under foreign laws are recognised in Switzerland, and taxation depends on the residency of the settlor and beneficiaries. FINMA-regulated Trustees uphold strict confidentiality and compliance standards.

7. Guide to Establishing and Managing a Swiss Company
Switzerland is an attractive location for businesses, offering low tax rates, political stability, and a prime European location. Incorporation typically takes three weeks, with options like SARL or SA structures. Flexible labour laws, VAT compliance, and favourable tax treatment for dividends and capital gains strengthen the benefits of operating in Switzerland.

Additional Information

For additional details on any of these topics or assistance with related services, please contact Christine Breitler at our Switzerland office: advice.switzerland@dixcart.com.