Typical Favorable Jurisdictions of substance (but not limited to)
- Cyprus foreword (Download the PDF)
- Tax differences among Company types in Cyprus (Download the PDF)
- Cyprus International Trusts (Download the PDF)
- One of the lowest corporation tax rate in Europe at 12.5%.
- Only 1 director and shareholder required without restrictions on foreigners
- Filing in English is permitted.
- Favorable tax regime for holding companies e.g. no tax on consolidation, CFC rules
- No taxation on inward or outward dividends and no Capital Gain Tax (CGT) on sales of securities.
- 40 double tax treaties (DTT) with other countries.
- Directors need not be present to open a local bank account.
- International Financial Reporting Standards (IFRS).
- Corporate documents are in English
- Although corporate income tax is subject to a flat rate at 35%, a system of tax refunds is in place so that upon dividend distribution, depending on the nature of the taxable profit, a 6/7ths, 5/7ths or 2/3rds tax refund of the corporate tax paid by the company, may be paid to the shareholder. The effective tax rate is therefore reduced to 5%.
- Furthermore, subject to anti abuse conditions, Malta’s tax system grants a full participation exemption, with respect to dividend income derived from a participating holding and to capital gains derived from the transfer of said holding
- Liberal tax regime with an extensive network of double tax treaties
- Obliged to register for tax and file returns
- the minimum share capital is now only €1
- A bank account in Holland is no longer necessary
- It is advisable to have a Dutch registered address and the majority of Dutch resident directors in order to qualify for the minimum substance in treaty benefits
- The share capital can be in any currency
- Shareholders’ liability is restricted to capital contribution;
- No nationality requirements
- Audited accounts must be filed
- Prestige, Image & Respectability
- Limited liability
- Only 1 director required without residency requirements
- Excellent infrastructure
- Top network of double tax treaties
- Accounting and Audit requirements
- Fully automated
- Profit distribution
Why go offshore?
- Less bureaucratic
- Tax Efficient
- Asset protection
- Risk management
- Cost efficient
Examples of International Business Companies (IBC):
- Quick incorporations at low cost
- The IBC’s offer a high degree of privacy.
- No tax except for annual government fees which is US$100
- Free from any reporting requirements including annual audits
- No requirement for a company secretary
- A bank account can be opened without the directors being present
- English is the official business language
- Fast and cost effective incorporations
- High level of anonymity
- No requirement to pay CGT, IHT & Withholding tax.
- Registered or bearer shares (subject to conditions) are permitted.
- 1 director & shareholder required of any nationality
- Board meetings if required can be held anywhere in the world.
- Directors can be individual or corporate bodies.
- There is no requirement to register initial or ongoing changes in Directors and Shareholders.
- There are lenient accounting and auditing requirements.
- No foreign exchange controls
- Corporate bank accounts can be opened without being present at the bank.
- Corporate Law and LLC Law based on corporate laws of the US State of Delaware
- Electronic registry allows for a 24/7 service
- Same day incorporation and document issuance
- No annual reporting or audits
- No requirement to file the names of Directors, Officers or Shareholders
- Statutorily exempt from Liberian income and withholding taxes
- OECD White Listed
- Independent and neutral domicile for parties in multiple jurisdictions
- Dual language filings permitted
- Seychelles IBC’s have no tax liabilities.
- No nationality restrictions and can be 100% foreign owned
- Only 1 director & shareholder required and can be the same person.
- Minimal reporting requirements; no audit or tax returns required.
- Cost efficient annual maintenance.
- No requirement for a Secretary.
- Very high degree of confidentiality with no public registers of directors/shareholders.
- No requirement for annual meeting to be held in the Seychelles
- No foreign exchange controls and funds can be easily transferred in an out of the country.
- English is widely spoken
- 100% foreign ownership permitted
- Only 1 director and 1 shareholder required
- Has a good financial regulatory framework and infrastructure
- Competitively priced
- No restrictions on hiring manpower if required with easy access to a large pool of well-qualified, highly training professionals
- High level of confidentiality
- A tax free environment with no exchange controls
- DTT network with the likes of New Zealand, China, Malaysia, Malta, France, Italy, India, Singapore, India, Germany and Finland
Other Examples: Hong Kong, Singapore, USA, Bahamas, Marshal Islands, Panama, Mauritius, Madeira…
Information on the above or any other jurisdictions are available upon request.