General Corporate Services
- Incorporation of Company Entities e.g. LTD, LLC, Partnerships, Foundations & Trust Registrations
- Provision of Address of Record / Billing Address
- Management & Administrational Services
- Mail Forwarding Service & Office Business Facilities
- Bank Account Opening
Corporation v Limited Liability Company (LLC)
An LLC is a hybrid between a corporation and a partnership. It is significant for tax purposes as it will generally be subject to tax once in the hands of each partner, hence its transparent nature. A corporation in the US for example will be taxed at a corporate level and then dividends and distributions will be taxable again in the hands of the shareholders.
Both afford limited liability and are separate legal entities. Generally LLCs have Members whereas Companies are run by Directors and Officers appointed by the Shareholders and they are answerable to the shareholders. Members of an LLC are answerable to each other. There are several more intricate differences.
Trusts v Foundations
In a nutshell, you could say that a Foundation is the civil law equivalent to a trust, offering HNWI a flexible structure to make future suitable arrangements for their families whilst protecting assets. It is comparable to a corporate alternative to a trust in that it keeps the main characteristics of a trust while holding additional benefits on a corporate scale. In jurisdictions that do not recognize trusts, a Foundation especially offshore may be established.
- Compliance, Due Diligence & Know Your Client
- Residence & Domicile Issues
- Investment Program
- Drafting of Legal Documents & Agreements
- Legal Opinions
- Trust matters
- Cyprus Tax residency
- Notional Interest Deduction
- IP Box regime in Cyprus
- Tax Incentives for Innovative SME’s
- Booking Keeping & Any Filing Requirements
- Preparation of Audit as Required by Law
- VAT Registrations with Quarterly Returns
- Tax Structuring and Planning
- Ship and Yacht Registrations in the Top Jurisdictions Typically Used.
- Merchant Shipping (Read More)
The majority of EU member states have applied for the tonnage tax regime that has helped competition. According to the Community State Aid to Maritime Transport, ship owners benefit from the scheme providing they have at least 60% of their tonnage under EU flags.
- Fund Registration & Management
- Private Wealth Planning & Introductions
- Property Investment
Substance has become an integral part of corporate activities. The emergence in an ever increasingly regulative environment with so much more emphasis on transparency, corporate governance and independence could bring about irreversible and disastrous effects in what was originally intended if not properly structured at the outset.
Further to the current financial situation the World’s governing authorities complacent in a hard-line stance particularly to the offshore arena under the scrutiny of the general public are taking a more active interest in this sector including the related Banking industry.
The OECD model convention states that a company may qualify for tax treaty benefits if it is a tax resident of the State in which it is registered in and is the beneficial owner of the income distribution. If an International group registers a Cyprus subsidiary or any other typical investment holding jurisdiction such as Malta or the Netherlands and that entity is effectively managed from abroad e.g. by the overseas parent company or by a foreign beneficial owner, the tax residency in the country of incorporation claiming treaty benefits may be at risk. Effectively management and control including where the major decision making is made is therefore a crucial factor in addressing substance.
In further investigations whether the effective management and control is within a specific jurisdiction, the foreign tax administration may want to identify whether the directors have the required skills to act and make the necessary decisions themselves and not simply act in a nominee capacity. Service providers must now take into consideration whether the directors are also employees, how many directorships they hold, the agreement indicating the provision of management services and in particular whether the directors appointed will only act upon the instructions of their client.
MSCS Consultants Ltd is totally independent. We do not provide nominee services. To facilitate matters we can make suitable management suggestions depending on your circumstances upon request.
Disclaimer: MSCS accepts no responsibility for the services obtained from third party service providers including a preferred provider. This information is provided purely as a courtesy and convenience.
Additional substance related services can be arranged to include:
- Office Rental
- Assistance with Employees / Insurances and Professional Indemnities
- Your Own Phone and Fax Line with Telephone Answering Services
- Corporate Website with your Own Server and Domain Name
Clearly, substance issues have become a lot more enhanced in recent years and many companies have already relocated certain sections of their business activities to strategically more favorable tax locations. MSCS will be pleased to assist you all of the way in locating the right partners to work with, in these matters.