Category: Residence and Citizenship

In this short article we cover some of the most attractive reasons for individuals and companies to setup or move to the Isle of Man. We’ll be looking at:

• A Short Modern-Day History of the Isle of Man
• Why do Business on the Isle of Man
• Why you should move to the Isle of Man?
• How to Move to the Isle of Man – Immigration Routes
• Happily Ever After – How Dixcart can help

But before getting into the benefits, it might be helpful to tell you a bit more about the island and its background.

A Short Modern-Day History of the Isle of Man

During the Victorian era, the Isle of Man represented an opportunity for British families to escape to their very own Treasure Island – only, with somewhat less pirates than Robert Louis Stevenson imagined. The development of key transport links such as regular steamship crossings, on-island steam engines and streetcars etc. made navigating to the jewel of the Irish Sea all the more attractive.

By the turn of the 20^th century the Isle of Man had become a thriving tourist destination, sold in the posters of days gone by as ‘Pleasure Island’ and a place to go ‘For Happy Holidays’. It is not hard to imagine why the idyllic island, with its rolling hills, sandy beaches and world class entertainment, represented a first choice for those looking to escape the hustle and bustle of a modernising Britain. The Isle of Man provided a convenient, exciting, safe and rewarding place for those who ‘do like to be beside the seaside’.

However, during the second half of the 20^th century, the Isle of Man simply couldn’t compete with the draw of low cost excursions to the continent and beyond. Thus, the island’s tourism sector declined. That is, save for the (semi)constant that has persisted (World Wars or COVID-19 permitting) – The Isle of Man TT Races – one of the world’s oldest and most prestigious motorcycle road racing events.

Today, the TT Races take place over multiple laps of an approx. 37 mile course and have run for well over a century; the current fastest average speed over the 37 miles is over 135mph and reaches a top speed of almost 200mph. To give an idea of scale, the Island’s resident population is approximately 85k, and in 2019 46,174 visitors came for the TT Races.

In the latter part of the 20^th century to this day, the Island has developed a flourishing financial services sector – delivering professional services to clients and advisers across the world. This has been made possible by the island’s self-governing status as a crown dependency – setting its own legal and tax regime.

In more recent years, the Island has pivoted again to develop beyond financial and professional services, with strong engineering, telecoms and software development, e-gaming and digital currency sectors, and more besides.

Why do Business on the Isle of Man?

A truly business-friendly government, ultra-modern telecoms services, transport links to all major UK and Irish business centres and very attractive rates of taxation, make the Isle of Man an ideal destination for all businesses and professionals alike.

Businesses can benefit from Corporate rates such as:

• Most types of business are taxed @ 0%
• Banking business taxed @ 10%
• Retail businesses with profits of £500,000+ are taxed @ 10%
• Income derived from Isle of Man land/property is taxed @ 20%
• No withholding tax on most dividend and interest payments

In addition to the obvious pecuniary benefits, the island also has a deep pool of well-educated expert workers, fantastic grants from the government to both encourage new businesses and provide vocational training and many working groups and associations in direct contact with local government.

Where relocating to the island is not physically possible, there are various options available to businesses wishing to be established on the Isle of Man and avail of the local tax and legal environment. Such activity requires qualified tax advice and the assistance of a Trust and Corporate Service Provider, such as Dixcart. Please feel free to get in touch to find out more in this regard.

Why you should move to the Isle of Man?

For individuals seeking to immigrate to the Island, there are of course attractive rates of personal taxation, including:

• Higher Rate of Income Tax @ 20%
• Income Tax Capped @ £200,000 of Contribution
• 0% Capital Gains Tax
• 0% Dividend Tax
• 0% Inheritance Tax

Further, if you are coming from the UK, the NI records are maintained in both jurisdictions and there is a reciprocal agreement in place so that both records are taken into consideration for certain benefits. State pension is however separate i.e. contributions in the IOM/UK only relate to IOM/UK state pension.

Key employees can also gain further benefits; for the first 3 years of employment, eligible employees will only pay income tax, tax on rental income and tax on benefits in kind – all other sources of income are free of Isle of Man taxes during this period.

But there is so much more: the blend of country and town living, huge number of activities on your doorstep, warm and welcoming community, high rates of employment, low rates of crime, great schools and healthcare, an average commute of 20 minutes and much, much more – in many respects the island is very much what you make it.

Furthermore, unlike some crown dependencies, the Isle of Man has an open property market, which means that those seeking to live and work on the island are free to purchase property at the same rate as local buyers. Property is far more affordable than in other comparable jurisdictions, like Jersey or Guernsey. In addition, there is no Stamp Duty or Land Tax.

Whether starting your career or moving with your family to take that dream job, the Isle of Man is a very rewarding place to be. You can register on the Locate IM’s talent pool, which has been developed to help people looking to relocate to the Isle of Man find employment opportunities as easily as possible. This is a free Government service that can be found here.

How to Move to the Isle of Man – Immigration Routes

The Isle of Man Government offer various visa routes for individuals seeking to relocate, using a blend of UK and Isle of Man processes, which include:

• Ancestral Visa – This route is dependent on the applicant having British ancestry no further back than grandparent. It is open to British Commonwealth, British Overseas and British Overseas Territories Citizens, along with British Nationals (Overseas) and Citizens of Zimbabwe. You can find out more here.
• Isle of Man Worker Migrant Routes – there are four routes currently available:
  • Worker Migrant Visa (You can find out more here).
  • Intra-Company Transfer Migrant Visa (You can find out more here).
  • Worker Migrant – Health and Care Visa (You can find out more here).
  • Tier 5 – Temporary Workers (You can find out more here).
• Business Migrant Routes – There are two routes:
  • Innovator Visa (You can find out more here).
  • Start Up Visa (You can find out more here).

Locate IM have produced a series of case studies that give great insight into people’s experiences with relocating to the Isle of Man. Here are two very different but equally inspiring stories – Pippa’s Story and Michael’s Story and this great video made in conjunction with a couple who moved to the island to work in the accountancy sector (anon).

Happily Ever After – How Dixcart can help

In many ways, the island can still be advertised as a convenient, exciting, safe and rewarding destination for business, professionals and their families to relocate. Whether it is assistance with creating a start-up or redomiciling your existing company, Dixcart Management (IOM) Ltd are well placed to assist. Further, where you are seeking to immigrate to the Island on your own or with your family, with our extensive network of contacts, we will be able to make appropriate introductions.

Locate IM have produced the following video, which we hope peaks your interests:

Get in touch

If you require further information regarding moving to the Isle of Man and how we can assist, please feel free to get in touch with Team at Dixcart via advice.iom@dixcart.com

Dixcart Management (IOM) Limited is licensed by the Isle of Man Financial Services Authority.

Portugal, a country with the oldest borders in Europe, is easily accessible in terms of travel to and from the rest of the world, which makes it a very popular destination. The archipelagos of the Azores and Madeira are autonomous regions of Portugal and, like the mainland, offer amazing weather, a relaxed lifestyle, superb cuisine, excellent wines, and stunning scenery.

The Portugal D7 Visa, which is often called the Passive Income Visa, is a good residence option for non-EU citizens/ EEA Nationals who want to live in Portugal.

The D7 Visa is also an excellent option for pensioners who have sufficient passive foreign income to support themselves. This income can be, for example, from: property rentals, financial investments, profits and dividends from a company, pensions, etc.

It is important to note that it is not possible to work in Portugal with a D7 Visa.

What do you need to do to apply for the D7 Visa?

STEP 1

The first step is to obtain a Portuguese tax number and open a bank account at a Portuguese bank. Once the bank account has been opened, you need to deposit a minimum amount of funds, as set out below:

• If you are applying on your own in 2024, you need to deposit EUR 9,840 per year, or more; OR
• If you are applying as a couple, you need to deposit EUR 14,760 per year, or more.

This is a low minimum income requirement, and if you can prove that your income is above this amount, your D7 Visa application has a better chance of being successful.

STEP 2

The second step is to secure long-term accommodation in Portugal. This includes either buying a property (no minimum amount required on the price), or renting a property for at least 12 months.

STEP 3

The third step is to submit an online application for an interview with the Portuguese Consulate, in your country of residence. 

After the Portuguese Consulate has concluded the analysis of your application and the documents submitted, they will issue a Visa which is valid for 4 months, and will allow you to travel to Portugal (two entries into the country), to submit your residence permit application to the Portuguese Immigration authorities (AIMA).

AIMA will analyse the application and then issue the D7 Visa, which will be valid for 2 years. During those 2 years, you need to stay in Portugal for at least 6 consecutive months or 8 intermittent months, per year.

If you continue to meet all the requirements, your D7 Visa will be renewable for another 3 years.

Other advantages of a D7 Visa

• Permanent Visa Free entry and movement in the Schengen Area, for up to 90 days out of any 180 days.
• Access to Educational institutions in Portugal (including those teaching in English, French and German).
• After a period of 5 years, being able to apply for permanent residence or Portuguese citizenship.

What is the Difference between a Golden Visa and a D7 Visa?

There are two major differences between the Golden Visa and a D7 Visa.

The first difference is that the Golden Visa requires a significant investment when compared to the D7 Visa.

In addition, the minimum stay requirements are very different: with a D7 Visa, the applicant cannot be outside of Portugal for more than 6 consecutive months in any 12 month period or 8 intermittent months over 24 months, in any one calendar year, whereas with a Golden Visa only 7 days a year, on average, is required to be spent in Portugal.

Why Should You Reach out To Dixcart?

Dixcart Portugal have helped hundreds of families with visas in Portugal and we acknowledge your trust to assist you with the process of applying for your D7 Visa and referring you to an independent legal advisor.

In addition, more than just a Visa is required when relocating to Portugal. Dixcart can provide tax planning, among other services, that can assist when relocating. Tax planning is considered necessary before your actual move to Portugal, as arriving unprepared may result in unfavourable tax consequences that could have easily been avoided.

Additional Information

Please contact Catarina Sardinha at the Dixcart office in Portugal at: advice.portugal@dixcart.com, for additional information. 

Background

In 2020 the Maltese government updated the citizenship legislation relating to citizenship by; birth, registration, naturalisation, dual and multiple citizenships, and exceptional services by direct investment.

A new residency route which can lead to Citizenship in Malta, was the outcome.

What are the Details of this New Residency Route?

• ‘Maltese Citizenship by Naturalisation for Exceptional Services by Direct Investment,’ provides foreign individuals and their families, who contribute to the economic development of Malta, a route to become citizens of Malta.

Malta is a member of the European Union as well as a Schengen Member State, and its citizens can travel, live, work, study and set up business in any of the member countries, with visa-free travel rights to more than 180 countries.

Community Malta Agency (‘Agency’), is the authorised Maltese Government Agency responsible for administering the processing of all applications leading to Maltese Citizenship.

What are the Criteria?

To apply for Maltese Citizenship by Naturalisation for Exceptional Services by Direct Investment, an applicant needs; to invest in the Maltese economy directly, make a donation and hold residential property.

Direct Investment

Applicants, who can prove residency status in Malta for 36 months, prior to the naturalisation, are required to make a direct investment of €600,000. Whilst applicants who can prove residency status in Malta for at least 12 months, prior to naturalisation, are required to make a direct investment of €750,000.

If the applicant is accompanied by qualifying dependants, a further investment of €50,000 per dependant needs to be made. 

An applicant cannot apply for a certificate of citizenship by naturalisation for exceptional services, before he/she has proved that he/she has become a resident of Malta for the minimum period required.

Philanthropic Nature of Direct Investment

Prior to the issue of a certificate of Maltese citizenship, the applicant must donate a minimum €10,000 to a registered philanthropic, cultural, sport, scientific, animal welfare or artistic non-governmental organisation or society, or as otherwise approved by the Agency.

In addition, the main direct investment made by each applicant will be used by the Government to finance projects coordinated by The National Development and Social Fund, across Malta.

Projects that Benefit from The National Development and Social Fund

The National Development and Social Fund agency (‘Fund’) was established to manage and administer 70% of the contributions received from the Individual Investor Programme of the Republic of Malta, set up under the Malta Citizenship Act Cap.188.

The Fund’s mission is to; contribute towards, promote and support significant projects and initiatives of national importance and of public interest, which are intended to develop and improve the economy, public services, and the general well-being of present and future generations.

Between July 2018 and June 2019, the total contributions, including property purchases, rents, and investments, collected through the Programme amounted to more than €271 million. This equates to approximately 2.11% of Malta’s GDP in the same period. The total amount collected, since the changes implemented in the 2020 citizenship legislation, exceed €930 million. Of these funds, approximately €515 million have been allocated to the National Development and Social Fund.

More Details about the Projects

The fund has invested in the following projects:

• €10 million to upgrade eight health centres and 54 clinics. Previously, the Fund awarded a grant of €950,000 to Mater Dei Hospital’s Cardiology Department to upgrade its two catheterisation suites, and €5 million to Puttinu Cares to purchase apartments for cancer patients and their families in London.
• In Feb 2019, a memorandum was signed to commit €50 million towards a social housing project. Five hundred new social housing units to be built, across 22 different sites. These sites are spread over 12 localities; Paola, Kirkop, Rabat, Żabbar, Mellieħa, Luqa, Żurrieq, Żebbuġ, Qormi, Siġġiewi, Qrendi and Marsascala.
• In Ħamrun, a planned roof garden of around 500m2, with more than 2,500 trees, shrubs and plants including mature carob, olive and oak trees, will be featured in the square. This garden will absorb around 900 kilograms of carbon dioxide from the atmosphere, whilst producing 660 kilograms of oxygen.
• Other investments allocated by the Fund include;  €1.5 million for Caritas, a €1.5 million investment in artistic heritage, and €3.5 million in Urban Green projects.

In 2020, the Fund received €27.8 million from Community Malta Agency, with the total proceeds received from inception being €599.8 million.

Investment in Education

An agreement was signed at the Wardija Resource Centre, part of the Maria Regina College, offering special education beyond the compulsory school age. With an investment of around €40,000, teaching will take place in a multisensory room, where skills related to students’ senses will be developed.

In addition, in collaboration with the University of Malta, a new garden will be planted to create a habitat for endemic butterflies and to enhance their reproduction chances. Another section is to have an apiary where students can learn and enjoy their free time.

At St Paul’s Bay’s Primary School, a room dedicated to creativity and innovation will be launched with an investment of €35,000. Teaching will be undertaken in interdisciplinary ways, mixing; science, technology, engineering, and the arts to increase students’ scientific, literacy and critical thinking.

Finally, at Naxxar’s Senior School, an investment of around €30,000 will be used for new curtains and a mechanised projector for the school’s stage. This is to encourage students to participate in visual and artistic activities, as this will help them learn to think creatively and develop critical thinking, which can be applied in all areas of learning.

Quota for the New Residency Route

It is important to be aware that a maximum quota of 400 applicants per year has been set, with a total maximum number of applicants set at 1,500, for the entire scheme.

Additional Information

If you would like further information regarding Maltese Citizenship by Naturalisation for Exceptional Services by Direct Investment, please contact the Dixcart office in Malta: advice.malta@dixcart.com or your usual Dixcart contact.

Dixcart Management Malta Limited Licence Number: AKM-DIXC

The High Potential Individual (HPI) visa is designed to attract top global graduates from prestigious universities around the work, who want to work, or look for work in the UK, following the successful completion of an eligible course of study equivalent to a UK bachelor’s degree level or above. The study must have been with an institution listed on the Global Universities List, the table of global universities that will be accepted for this visa route as awarding institutions, which is updated regularly.

The new High Potential Individual route, launched on 30 May 2022, is an unsponsored route, granted for 2 years (Bachelors and Masters holders), or 3 years (holders of a PhD).

Eligibility Requirements

• The HPI is based on a points-based system. The applicant needs to obtain 70 points:
  • 50 points: The applicant must, in the 5 years immediately before the date of the application, have been awarded an overseas degree level academic qualification which ECCTIS confirms meets, or exceeds, the recognised standard of a UK bachelor’s or UK postgraduate degree. From an institution listed on the Global Universities List.
  • 10 points: English Language requirement, in all 4 components (reading, writing, speaking and listening), of at least level B1.
  • 10 points: Financial requirement, applicants must be able to demonstrate that they can support themselves within the UK, with a minimum cash fund of £1,270. Applicants who have lived in the UK for at least 12 months under another immigration category, do not have to meet the financial requirement.
• If the applicant has, in the last 12 months before the date of application, received an award from a Government or international scholarship agency covering both fees and living costs for study in the UK, they must provide written consent to the application from that Government or agency.
• The applicant must not have been previously granted permission under the Student Doctorate Extension Scheme, as a Graduate or as a High Potential Individual.

Dependants

A High Potential Individual can bring their dependant partner and children (under the age of 18) to the UK.

Staying Longer in the UK

The High Potential Individual route is not a route to settlement. A High Potential Individual is not able to extend their visa. However, they may be able to switch to a different visa instead, for example a Skilled Worker visa, Start-up visa, Innovator visa, or Exceptional Talent visa.

Additional Information

If you have any questions and/or would like tailored advice on any UK immigration matter, please speak to us at: advice.uk@dixcart.com, or to your usual Dixcart contact.

Switzerland is an enchanting country, blessed with spectacular hiking and skiing trails, beautiful rivers and lakes, picturesque villages, Swiss festivals throughout the year, and, of course, the spectacular Swiss Alps. It appears on almost every bucket list of places to visit but has succeeded in not feeling over-commercialised – even with the tourists flocking to the country to try the world-famous Swiss chocolates.

Switzerland features almost at the top of the list of most attractive countries for high-net-worth individuals to live. It is one of the world’s wealthiest countries and is also known for its impartiality and neutrality.

Switzerland offers an exceptionally high standard of living, first-rate health service, outstanding education system, and boasts a plethora of employment opportunities.

Switzerland is also ideally situated for ease of travel; one of the many reasons high-net-worth individuals choose to relocate here. Perfectly situated in the middle of Europe means moving around could not be easier, especially for individuals who regularly travel, internationally.

Swiss Residence

There are no restrictions imposed on permanent residence for EU/EFTA nationals and these individuals enjoy priority access to the labour market. Should an EU/EFTA citizen wish to live and work in Switzerland, they can freely enter the country but will need a work permit to stay more than 3 months.

Regarding EU/EFTA nationals who do not want to work in Switzerland, the process is even more straightforward. Individuals must show they have sufficient funds to live in Switzerland and take out Swiss health and accident insurance.

The process is a bit longer for non-EU and non-EFTA (European Union Free Trade Association) nationals. Those who wish to live and work in Switzerland are allowed to enter the Swiss labour market, but must be appropriately qualified (such as managers, specialists, and those with higher education qualifications). They will also need to be registered with the Swiss authorities in order to obtain a work visa, and they will need to apply for an entry visa from their home country.

Non-EU/EFTA nationals who want to move to Switzerland, but not to work, are divided into two age categories. Depending on which category the individual falls into (over 55 or under 55), certain criteria must be met (more information can be provided on request: advice.switzerland@dixcart.com).

Taxation in Switzerland

One of the greatest motivations for moving to Switzerland is the attractive tax regime available to individuals who choose to live there. Switzerland is divided into 26 cantons and each canton has its own cantonal and federal taxes that generally impose the following taxes: income, net wealth, and real estate.

A significant advantage of the Swiss tax regime is that the transfer of assets in Switzerland, before death (as a gift), or on death, to a spouse, or to children and/or grandchildren is exempt from gift and inheritance tax, in most cantons. In addition, capital gains are generally also tax free, except in the case of real estate.

The federal and cantonal tax laws of most cantons provide for a special Lump Sum Tax Regime for foreigners who move to Switzerland for the first time, or after an absence of ten years, and who will not be employed or commercially active in Switzerland. It is an extremely attractive tax regime as it enables individuals to manage their worldwide investments from Switzerland.

Individuals benefiting from the Lump Sum System of Taxation are not subject to Swiss taxation on their worldwide income and net wealth, but on their worldwide expenditure (living expenses). The minimum requirement for calculating income tax based on expenses for individuals with their own household, is the equivalent of seven times the annual rental value of their principle residence in Switzerland. In addition, a minimum taxable income of CHF 400,000 is assumed for direct federal taxation. Cantons may also define minimum expense thresholds, but the amount is at their own discretion. Some cantons have already stated their minimum threshold amounts and these will vary from canton to canton.

Living in Switzerland

Although Switzerland has a variety of beautiful towns and alpine villages to live in, expats and high-net-worth individuals are mainly drawn to a few specific cities. At a glance, these are Zürich, Geneva, Bern and Lugano.

Geneva and Zürich are the biggest cities due to their popularity as centres for international business and finance. Lugano is located in Ticino, the third most popular canton, as it is close to Italy and has a Mediterranean culture many expats enjoy.

Geneva

Geneva is known as the ‘international city’ in Switzerland. This is due to the high number of expats, the UN, banks, commodity companies, private wealth companies, as well as other international companies. Many businesses have set up head offices in Geneva. However, the main attraction for individuals, continues to be the fact that it is in the French part of the country, has a well-looked-after old town full of history and culture and boasts Lake Geneva, with a magnificent water fountain which reaches 140 meters into the air.

Geneva also has fantastic connections to the rest of the world, with a large international airport and connections to the Swiss and French rail and motorway systems.

In the winter months, residents in Geneva also have very easy access to the Alp’s best ski resorts.

Zürich

Zürich is not the capital of Switzerland, but it is the largest city, with 1.3 million people within the canton; an estimated 30% of the residents in Zürich are foreign nationals. Zürich is known as the Swiss financial capital and is home to many international businesses, especially banks. Even though it gives the image of high-rise buildings and a city lifestyle, Zürich has a beautiful and historical old town, and an abundance of museums, art galleries and restaurants.  Of course, you are also never too far from the lakes, hiking trails and ski slopes if you love being outdoors.

Lugano and the Canton of Ticino

The canton of Ticino is the southernmost canton of Switzerland and borders the canton of Uri to the north. The Italian-speaking region of Ticino is popular for its flair (due to its proximity to Italy) and fantastic weather.

Residents enjoy a snowy winter but in the summer months, Ticino opens its doors to tourists who flood to its sunny coastal resorts, rivers and lakes, or sun themselves in the town squares and piazzas.

In Switzerland, four different languages are spoken, and English is well spoken everywhere.

Additional Information

I hope this article has inspired you to visit Switzerland and to consider this incredible country as a place of residence. No matter which canton draws your attention, or which city you decide to settle in, the rest of the country, and Europe, is easily accessible. It may be a small country, but it offers; a diverse range of places to live, a dynamic mix of nationalities, is headquarters to many international businesses, and caters to a large range of sports and leisure interests.

The Dixcart office in Switzerland can provide a detailed understanding of the Swiss Lump Sum System of Taxation, the obligations that need to be met by applicants and the fees involved. We can also give a local perspective on the country, its people, the lifestyle, and any tax issues. If you would like to visit Switzerland, or wish to discuss moving to Switzerland, please do get in touch: advice.switzerland@dixcart.com.

The procedure for relocating to Switzerland is made easier for both EU/EFTA nationals and non-EU/EFTA nationals, if the new resident forms a Swiss company and is employed by it.

If you are looking for a high quality of life in one of the world’s most economically and politically stable countries, living in Switzerland could provide you with the ideal answer. Not only will you find yourself at a central hub for travel to over 200 international locations, but you will also have access to the beautiful scenery of the Alps and picturesque lakes.

There are two options for moving to Switzerland – but the main question is do you wish to work once you have moved?

This article explores the following:

1. Why Switzerland?
2. Who Can Move to Switzerland?
3. Forming or Investing in a Swiss Company
4. Criteria for Forming a Swiss Company
5. How to Invest in a Swiss Company?
6. Benefits – Tax and Residence
7. Living in Switzerland

1. Why Switzerland?

Switzerland is an attractive jurisdiction to start and operate a business, as a location for individuals and for family protection and safety. 

Advantages include:

• Located in the centre of Europe.
• Economic and political stability.
• High regard for personal privacy and confidentiality.
• Most ‘innovative’ and “competitive” country in the world with various strong industries.
• A well-respected jurisdiction with an excellent reputation.
• A high quality and multilingual local workforce.
• Low rates of corporate tax for Swiss companies.
• Premier destination for international investment and asset protection.
• Major commodity trading centre in the world.
• Hub for HNWIs, international families and a wide variety of professionals including lawyers, family offices, bankers, accountants, insurance companies.

2. Who can Move to Switzerland?

• EU/EFTA nationals: enjoy priority access to the labour market. They can freely enter the country but will require a work permit. The individual will need to find a job and the employer must register the employment before the individual can actually start to work.
• Non-EU/EFTA nationals: are allowed to enter the Swiss labour market if they are appropriately qualified, for example managers, specialists, and those with higher educational qualifications. The employer needs to apply to the Swiss authorities for a work visa, while the employee applies for an entry visa from their home country. The work visa will allow the individual to live and work in Switzerland.

3. Forming or Investing in a Swiss Company and Becoming a Director or an Employee of the Company

The establishment of a Swiss company is one of the most popular routes for individuals relocating to Switzerland. This is because EU/EFTA and non-EU/EFTA nationals can form a Swiss company, be employed by it, reside in Switzerland, and benefit from the attractive tax regime.

Any foreign national can form a company and therefore potentially create jobs for Swiss nationals. The owner of the company is eligible for a residence permit in Switzerland, as long as he/she is employed by the company in a senior capacity.

4. What are the Criteria?

In principle, non-EU/EFTA nationals need to form a company which must:

• generate an annual minimum turnover of CHF 1 million, and
• create new jobs exploiting new technologies and/or the development of the region and contribute to the economic development of the country.

The company must produce a business plan detailing how the amount to be invested will generate a turnover of CHF 1million or more per annum, in the ‘near’ future. The business plan also needs to show that the company will achieve this turnover in a specified number of months, not necessarily in the first year, particularly if the company is a start-up.

The types of economic development objectives for the company, which are regarded positively in Switzerland, include: opening up new markets, securing export sales, establishing economically significant links abroad, and the creation of new tax revenue. Precise requirements vary by canton and more information can be provided on request.

Alternatively…

5. Investment in a Swiss Company

Alternatively, EU and non-EU/EFTA applicants can choose to invest in a company which is struggling to expand, as it lacks the necessary funding.

For non-EU/EFTA applicants this new funding should then enable the company to create jobs and assist the Swiss economy to expand. The investment must add economic value to a particular Swiss region.

6. Benefits of a Swiss Company – Tax and Residence

• Taxation of Swiss Companies

Swiss companies can enjoy a zero-tax rate for capital gains and dividend income, depending on the circumstances, and Trading companies are taxed as follows:

• The effective cantonal and federal corporate income tax rate (CIT) is between 12% and 14% in most cantons. The Geneva corporate tax rate is 13.99%.

Swiss Holding Companies benefit from a participation exemption and do not pay tax on profits or capital gains arising from qualifying participations. This means that a pure Holding Company is exempt from Swiss tax.

Withholding Tax (WHT)

• There is no WHT on dividend distributions to shareholders based in Switzerland and/or in the EU (due to the EU Parent/Subsidiary Directive).
• If shareholders are domiciled outside Switzerland and outside of the EU, and a double tax treaty applies, the final taxation on distributions is generally between 5% and 15%.

Double Tax Treaties

Switzerland has an extensive double tax treaty network, with access to tax treaties with over 100 countries.

For more information about Swiss Companies, please read our article: Formation of a Swiss Company.

• Taxation of Individuals

Each canton sets its own tax rates and generally imposes the following taxes: income, net wealth, real estate, inheritance, and gift tax. The specific tax rate varies by canton and is between 21% and 46%.

In Switzerland, the transfer of assets, on death, to a spouse, children and/or grandchildren is exempt from gift and inheritance tax, in most cantons.

Capital gains are generally tax free, except in the case of real estate. The sale of company shares is one of the assets, that is exempt from capital gains tax.

7. Living in Switzerland

Switzerland ranks among the top countries in the world in which to live due to its high quality of living and reputation as a centre of international trade and finance. It is one of the world’s wealthiest countries and is also known for its impartiality and neutrality.

Switzerland is blessed with spectacular hiking and skiing trails, exclusive swimming spots in the many rivers and lakes, picturesque villages, Swiss festivals throughout the year, and, of course, the Swiss Alps which look spectacular during any season.

Switzerland offers an exceptionally high standard of living, first-rate health service, outstanding education system, and boasts a plethora of employment opportunities.

Switzerland is one of 26 countries in the ‘Schengen’ area and a Swiss residence permit will enable you to enjoy full Schengen travel rights. It is therefore ideally situated for ease of travel; one of the many reasons high-net-worth individuals choose to relocate here. Perfectly situated in the middle of Europe means moving around could not be easier, especially for individuals who regularly travel, internationally.

Although Switzerland has a variety of beautiful towns and alpine villages to live in, high-net-worth individuals are mainly drawn to a few specific cities. At a glance, these are Zürich, Geneva, Bern, and Lugano. Geneva and Zürich are the biggest cities due to their popularity as centres for international business and finance. Ticino is the third most popular canton, as it is located close to Italy and has a Mediterranean culture.

Additional Information

If you would like additional information regarding moving to Switzerland and forming a Swiss Company, please contact Christine Breitler at the Dixcart office in Switzerland: advice.switzerland@dixcart.com.

Non-Swiss nationals are allowed to stay in Switzerland as tourists, without registration, for up to three months. After three months, anyone planning to stay in Switzerland must obtain a work and/or residence permit, and formally register with the Swiss authorities.

How can I Become a Legal Swiss Resident?

There are two alternative routes to become a Swiss resident:

• By working in Switzerland
• By not working in Switzerland and/or by being retired
  • The ‘Normal System of Taxation’
  • The ‘Lump Sum System of Taxation’

Working in Switzerland

The acquisition of a Swiss work permit allows a non-Swiss national to become a Swiss resident.

There are three ways to be entitled to work in Switzerland:

• Being hired by an existing Swiss company.
• Forming a Swiss company and become a director or an employee of the company.
• Investing in a Swiss company and become a director or an employee of the company.

When applying to work in Switzerland and/or for residence permits, different regulations apply to EU/EFTA nationals, compared to nationals of other countries.

• It is a straightforward process for EU/EFTA citizens as they enjoy priority access to the labour market in Switzerland.
• Non-EU/EFTA nationals can work in Switzerland as long as they are appropriately qualified, for example managers or specialists and/or with higher education qualifications.

An alternative route is for non-Swiss nationals to form a Swiss company and obtain a residence permit in Switzerland. Relevant individuals must be employed by the company that they establish in Switzerland.

Non-EU/EFTA businesses need to create jobs and business opportunities in Switzerland. The precise number and nature varies depending on the particular canton in which the business is located.

Normal System of Taxation – Not working in Switzerland

The process is relatively straightforward for EU/EFTA nationals wanting to live, but not work, in Switzerland and taxed via normal system of taxation.

Individuals must have sufficient financial resources to live in Switzerland and ensure that they will not become dependent on Swiss welfare and they also need to take have Swiss health and accident insurance

For Non-EU/EFTA nationals the process is less straightforward but is achievable, under the correct circumstances.

Lump Sum Taxation – Not working in Switzerland

A non-Swiss national, who does not work in Switzerland, can apply for Swiss residency under the system of ‘Lump Sum Taxation’.

• The taxpayer’s lifestyle expenses are used as a tax base instead of his/her global income and wealth. There is no reporting of global earnings and assets.

Once the tax base has been determined and agreed with the tax authorities, it will be subject to the standard tax rate relevant in that particular canton.

Work activities outside Switzerland are permitted. Activities relating to the administration of private assets in Switzerland can also be undertaken.

Third country nationals (non-EU/EFTA), may be required to pay a higher lump-sum tax on the basis of “predominant cantonal interest”. This will depend on a number of factors and varies case by case.

How can an Individual Become a Swiss Citizen?

• An EU or non-EU/EFTA national must have lived in Switzerland for at least 10 years, to be able to apply for a Swiss passport.
• If an EU or non-EU/EFTA national is the spouse of a Swiss national, they need only to have lived in Switzerland for 5 years.

What Advice and Support can Dixcart in Switzerland Provide?

Dixcart in Switzerland is experienced in assisting individuals to move to this country having assisted:

• Individuals working for Swiss companies
• Individuals seeking to establish a Swiss company
• Individuals based in or moving to Switzerland and working for foreign companies
• Foreign companies looking to set up a Swiss branch or companies
• Those seeking to take advantage of the Lump Sum System of Taxation

Professional support includes guidance regarding:

• Choice of location to move to in Switzerland: canton and city.
• Lump Sum Taxation: the criteria, how to apply for it, the taxation implications for the specific circumstances (dependent on the canton where the individual chooses to live). 
• For employees, assistance regarding: salary calculations, social security calculations and payments, and payroll tax calculations and payments.
• For those seeking to set up a business: bookkeeping, business plans, payroll, preparation of annual accounts, preparation of annual returns, Swiss insurance expertise, Swiss social security expertise, and value added tax reporting and payment (VAT).

Additional Information

If you would like additional information regarding moving to Switzerland and the assistance that Dixcart Switzerland can provide, please contact Christine Breitler at the Dixcart office in Switzerland: advice.switzerland@dixcart.com.

Background

As of 6th April 2022  a number of new UK immigration rules came into effect.

The Tier 1 (investor) visa had already been closed to new applicants on 17 February 2022.

A summary of the key changes is detailed below.

Overseas Representatives Business Category

The Overseas Representative Businessperson category, commonly known as Sole Representative will no longer exist. The Overseas Media Person category will remain unaffected. Those currently holding permission under the Sole Representative category will be unaffected.

Global Business Mobility Routes

The Intra-Company Transfer routes have been revamped and will be known as the Global Business Mobility routes. Those under this category will not be eligible for permanent residence.

The new Global Business Mobility route creates 5 sub-categories as set out below. It means that a sponsor licence holder will need to hold licences under the relevant sub-categories to be able to be a sponsor:

1. The Senior or Specialist Worker which replaces the Intra-Company route and is applicable to senior managers or specialist employees who are being assigned to a UK linked entity for a temporary assignment.
2. Graduate Trainee which replaces the Graduate Trainee Intra-Company route and is designed for those on a dedicated Graduate programme outside of the UK, and who are required to be assigned to the UK for part of the programme.
3. UK Expansion Worker which is for senior managers or specialist workers being assigned temporarily to the UK to establish an UK entity or to undertake work related to a business expansion to the UK. The applicant would need to meet the points criteria (60 points) and be granted a Certificate of Sponsorship. This will mean that the employer must obtain a sponsor licence by requesting a provisional rating, with the applicant holding the role of authorising officer. The maximum stay allowed would be 5 years in any 6-year period.
4. Service Supplier which is for overseas workers who are undertaking temporary work assignments in the UK, where the worker is either a contractual service supplier employee or a self-employed independent professional. The applicant would need to meet the points criteria (40 points) and be granted a Certificate of Sponsorship. There are no requirements to meet the salary point requirements. The maximum stay allowed would be 5 years in any 6-year period.
5. Secondment Worker which is for overseas workers who are undertaking temporary work assignments, where the assignment is part of a high value contract or investment by their overseas employer. The applicant would need to meet the points criteria (40 points) and be granted a Certificate of Sponsorship. There are no requirements to meet the salary point requirements, but the contract must have been registered with the Home Office. The maximum stay allowed would be 5 years in any 6-year period.

Introduction of the High Potential Individual (HPI) and Scale-up Routes

The HPI introduces an elite points-based route to attract the brightest and best to the UK to maintain the UK’s status as a leading international hub for emerging technologies. Applicants must have a bachelor’s or postgraduate degree from one of the Global Universities, listed by the Home Office, within 5 years of the date of application.

The Scale-up route introduces an elite points-based route to attract the brightest and best to the UK, to maintain our status as a leading international hub for emerging technologies. A job offer must be received from an authorised UK scale-up company. The scale-up company would need to demonstrate that they have an annualised growth of at least 20% for the previous 3-year period in terms of turnover or staffing, as well as having a minimum of 10 employees at the start of the 3-year period.

Additional Changes

Changes have been made to the rules relating to Settlement based on Family Life and Private Life, to make the requirements simpler to understand.

Policy Guidance

A further update will be provided once the policy guidance has been released.

Further Information and Advice

If any of the changes above affect you and/or you need assistance regarding immigration to the UK, as an individual or as an employer, please speak to Peter Robertson at: advice.uk@dixcart.com.

Digital Nomads – the Background

Digital nomads are remote workers who travel to different locations regularly. They use modern technology to work from coffee shops, hotels, co-working spaces, or libraries with a Wi-Fi-connected laptop or smartphone from anywhere in the world.

Digital nomads tend to be freelancers or entrepreneurs who are self-employed, working for themselves or for companies as independent contractors.

In the past it has been difficult for entrepreneurs and freelancers to apply for traditional visas as either a contract with a local entity was required, or a letter of invitation. A tourist visa, for example, is not suitable as the individual might want to stay for a more extended period.

The Malta Nomad Residence Permit

The Malta Nomad Residence Permit can easily be obtained by; remote workers, digital nomads, and freelancers and it grants the holder a legal right to reside in Malta and travel visa free throughout the Schengen Member States.

About Malta

Malta has long been famous for its expat-friendly environment, which is well illustrated by the large expat community in Malta. Thanks to its favourable legislative system and tax benefits, the island is home to many foreign companies.

It is a small country in size but has a cosmopolitan soul. There are many cafes, bars, restaurants, and co-working spaces that make life easier for digital nomads. In addition, it is now one of the very few countries in the world with 5G nationwide coverage.

Along with its digital nomad-friendly environment, it also has everything an ideal island would have; beaches, 300 sunny days a year, a relaxed way of life, excellent seafood, and a lot of fun. Malta has it all and is a perfect base for remote working.

Eligibility Criteria for Malta Nomad Residence Permit

There is a specific set of rules for the program.

Applicants must:

• Be a third-country national (non-EU)
• Have a monthly income of €3,500 (gross of tax) for a single applicant
• Have a work contract for an employer that is registered in a country other than Malta, OR
• Be a partner/shareholder in a company that is registered in a country other than Malta, OR
• Offer freelance services to clients whose permanent establishments are in  countries other than Malta, and with whom the applicant has a contract(s)
• Have a valid travel document
• Have health insurance covering Malta
• Present a property rental or property purchase agreement

Cost of Application and Timeframe for Malta Nomad Residence Permit

The government fee for the main applicant is €300, with an additional €300 fee payable for each family applicant.

Applicants who intend to spend up to 180 days in Malta will be issued with a National Visa, while those who plan to spend up to 365 days or more will be issued with a Residence Permit.

Processing applications takes approximately 30 days, from receipt of all the required documentation and application forms.

Which Family Members can be Included?

The main applicant can include dependent family members. It is possible to add a spouse and minor children, as well as adults who are financially dependent on the main applicant.

Malta recognizes same-sex unions. A same-sex partner in a committed relationship for a defined period, can be included in an application.

Applicable Taxes

Nomad residence permit holders are not subject to personal income tax as they are  expected to pay tax in their country of origin. However, nomad residence permit holders will be subject to consumption tax (VAT) in the same manner as all Malta residents. 

How Can Dixcart Assist?

If you would like further information regarding Malta Nomad Residence Permit, please speak to Jonathan Vassallo: advice.malta@dixcart.com, at the Dixcart office in Malta or to your usual Dixcart contact.

Dixcart Management Malta Limited Licence Number: AKM-DIXC