Intermediate Group Holding Company: Telco Ltd, a company incorporated and managed in South Africa and engaged in telecommunication services, is going to invest in China.
Intermediate Finance Company: An Israeli investor is investing in the Czech Republic. A substantial part of the investment will be financed with debt. As the Czech withholding tax on interest paid to Israel is 10%, he wonders whether this withholding tax can be avoided by structuring the loan through a third country.
Licensing company: Zoomcopter holds the worldwide patents on an invention and it wonders how the exploitation of the patents can be arranged in a tax-effective manner.
Personal service company: Albert Smith is currently working in Luxembourg as an independent IT consultant through a Luxembourg management company. Therefore, he is currently paying Luxembourg taxes (rates up to 38%). Mr. Smith is going to conclude a new service contract to work in Italy for a US-company. The US company has a European office in the UK. It is contract work and the US company is using Albert's services by sub-contracting him out to one of its clients in Italy.
International trading companies: Yuri Ivanov lives in Russia. He is purchasing and selling shoes. He buys the shoes from Italy and sells them to department stores in France, Germany and Spain. Mr. Ivanov wonders whether he can structure his business in a tax-effective manner, for example by using an offshore company.
Electronic products business to business case study: Company A is based in the UK and has been selling computer software to businesses for a number of years using a mail-order catalogue and a small direct sales force. It has successfully set up a UK web site that allows the purchase and shipping of software to customers' homes and businesses. The web-site has started to generate significant quantities of non-UK orders from around the world.
Electronic products consumer case study: Company Z is a privately-owned, UK-based retailer of CDs through its network of high street shops, which have been trading for the last 25 years. It has not yet established a web site, and is keen for this to be combined with digital delivery of music to customers if this is possible. Company Z employs Netbased Ltd, a e-commerce consultancy firm, to produce a report on the introduction of a web site and the feasibility of introducing digital products.
Physical products business to business case study: CompDirect is an established UK based mail order company supplying pre-assembled computer equipment and sundries to companies throughout Europe. Founded in the UK in 1974, CompDirect expanded into continental European markets in the 80's, and began to develop strongly into Eastern Europe in the mid 90's. The main functions of the business including management, world-wide procurement, marketing and sales are conducted from the UK head office in London.
Physical products consumer case study: Toyco is a newly-established company which will retail toys exclusively through the Internet from its headquarters in an offshore jurisdiction. It is owned by two Canadian businessmen, who between them have previous experience of offshore companies, e-commerce and toy retailing; they see substantial tax and cost advantages to be gained from an offshore location.
Offshore banking and financial services case study: Saxon Brothers is a private bank established in the mid-19th century with branches in London and New York. In the late 20th century the available range of investment opportunities and techniques expanded very rapidly, and this proved challenging for Saxon Brothers, as its high-net-worth investors became more sophisticated and alternative types of investment appeared offering higher rates of return.
Offshore corporate functions case study: Mattsohn & Mattsohn (M & M) is a major European supplier of cosmetics, health care products and toiletries under many well-known brands. It has parallel listings in Frankfurt and London. In 1975 it acquired a 50% stake in Empire Essences Ltd (EEL), a British company with extensive interests in essential oils throughout what had been the British Empire.
Over the past twenty years increasing client demand for International Financial Facilities and International Tax Planning solutions. The political and economic catalysts that influence the growth of our services are:
International Financial Service Centers: a business location possessing elements of the following four characteristics: Business is transacted mainly with non-residents. Financial regulation and corporate legislation are designed to attract international business. Confidentiality in financial affairs is paramount. Advantageous tax regimes are deliberately managed.
These general notes refer to companies incorporated in jurisdictions that follow UK law. Company Name: The registrar has the power to refuse registration of any name considered undesirable, confusing, offensive or too like that of an existing company. Words including trust, investment, bank and insurance can only be used if the company is specifically licensed to undertake the indicated activity. The criteria for name selection may vary by jurisdiction.
If you are an individual (natural person) who is resident in an EU Member State, and earn bank interest or other savings income on deposits or investments held in your own name in another EU Member State, third country or territory covered by the Directive, then it is likely that you will be affected by the STD. The Directive does not apply to persons (including EU Nationals) who are resident outside the 25 Member States of the EU or the Crown Dependencies of the UK (Jersey, Guernsey and the Isle of Man). Any new countries joining the EU will be obliged to accept the information-sharing variant of the Directive, and their residents will be caught by the STD as and when those countries accede to the EU.
The Directive came into operation on 1st July, 2005.
Switzerland is a 'code' country, and business entities are governed by the Civil Code. As in all civil law jurisdictions, formation and administration of companies tends to be considerably more bureaucratic than in common law jurisdictions. Although the Civil Code is at Federal Level, businesses are domiciled in a particular canton. Each canton maintains a Commercial Register (Registre de Commerce), and the mandatory entries in the Register of subscribers, directors, capital structure etc have strict legal force. The Register is a public document.
In July, 2006, the European Commission ordered the government of Luxembourg to dismantle its system of tax breaks for financial holding companies, after concluding that the preferential tax regime in favour of Luxembourg’s Exempt, Milliardaire and 1929 Financial Holding companies violates EC Treaty state aid rules. (The existing regimes are described in Offshore Legal and Tax Regimes.) "It distorts competition and trade by altering the level playing field between financial undertakings and induces them to create dedicated structures in Luxembourg to reduce their current tax liabilities," the EC stated.
Cyprus Private Company Limited by Shares: The relevant legislation is Cyprus Companies Law, Cap. 113, which is virtually a copy of the English 1948 Companies Act. A private company is one which by its articles: Restricts the right to transfer its shares. Limits the number of its members to 50. Prohibits any public subscription to shares or debentures. The Companies (Amendment) Law of 2000 (Law 2(I)/2000) introduced single-member companies. The Companies (Amendment) (No. 3) Law of 2000 (151(I)/2000) introduced new provisions as to the validity of transactions of companies and as to the information which must be included in the official documents of companies.
Belize International Business Company: An International Business Company (IBC) is formed under the International Business Company Act 1990. An IBC is formed by filing Articles and Memorandum of Association along with the required fees. The following are the main characteristics of an IBC: There is no minimum paid up capital requirement, and capital may be expressed in foreign currency; An IBC may issue bearer shares and shares of no par value; but bearer shares must be held in the custody of a local registered agent; Subscribers may include an individual, a corporation or a Trust;
The UK's three IOFCs, Jersey, Guernsey and the Isle of Man have developed in different ways; the Isle of Man is not dominated by any one particularly activity, but has across-the-board strength in the financial sector, with substantial business in banking, fund management and captive insurance. The Isle of Man has also encouraged manufacturing and trading operations, which can be fiscally offshore while staying within the EU's VAT regime.
Maltese company law derives chiefly from civil or 'Roman' law, rather than common law. A new Companies Act 1995 replaces the old Commercial Partnerships Ordinance, and sets up a new regime for commercial entities under the Registrar of Companies. Companies set up under the old regime had until 1st January 1998 to convert themselves into the new formats, except that 'Offshore Companies', which can now no longer be formed, have 10 years to adapt. Shipping companies, and, while they survive, offshore companies, continue to be subject to the old Commercial Partnerships Ordinance.
It is important to us to forge a good relationship with each of our clients in order to have a better understanding of their needs and objectives. One aspect of this will be the investment brief which forms the basis for the service we provide and is crucial for its success.
Real property companies: Ferenc Kiss, a Hungarian high net-worth individual living in Budapest, is investing substantial amounts of his wealth in real property, both in Hungary and in other Central and Eastern European countries.
Income arising overseas: Nancy Johnson, a Canadian individual, has acquired some luxury apartments in France along the coast of the Mediterranean. It is her intention that the apartments will be rented out to third parties. In case of sale of the apartments or when Nancy dies, capital gains taxes and inheritance taxes should be avoided or reduced as much as possible.
Estate Planning: Bernard Shaw, a widower of 65, is planning to remarry with a Canadian woman and emigrate to Canada. At present, Mr. Shaw is resident in the UK. He has two children; a son living in the Bahamas, and a daughter who married a German man and has been a resident of Germany for more than 10 years. His new wife also has two children from her first marriage; a son who lives in Brazil, and a daughter living in the United States.
Divesting of personal assets: Olga Barschefsky, an individual living in Moscow, is a chemical engineer and managing director of a Russian company engaged in the manufacturing of masks protecting against biological and chemical weapons. The Russian company has received a license for the production of these masks from Olga who holds the world-wide patents on a new revolutionary invention which is used when producing the masks.
Pre migration planning: Mr. Abdullah, an executive working for a big oil company in Kuwait and also resident in Kuwait (0% income tax) is sent by his employer to Germany to become the CEO European operations of his company. It is expected that he will stay in Germany for a long period of time (at least 8 - 10 years) and he takes his family with him to Germany.
+44 70 40 40 15 20
