Roydon Snelgar

Bearer Share Companies

11 September 2018

Bearer share companies are companies where the individual shareholders are not known to the company. The bearer share companies do not know anything about their shareholders—not their names, addresses, or the size of their shareholdings. Instead, each shareholder’s ownership in the bearer share company will be evidenced by their physical possession of a share certificate…

Luxembourg Holding Company

6 September 2018

  A Luxembourg Holding Company is a resident company in the tax haven of Luxembourg which operates subsidiaries. Guardian Industries Corp, Amazon, Millicom, PayPal, Apple iTunes, DuPont Teijin Films, Fanuc Robotics, and Skype have all chosen Luxembourg for their European business headquarters. In addition, ArcelorMittal (the world’s leading steel producer), SES (the world’s largest satellite…

Protected Cell Companies

4 September 2018

Protected cell companies (PCCs) were originally developed in Guernsey in 1997 to provide a solution for companies who wanted to take advantage of the risk management solutions offered by a traditional single parent captive insurance, but who did not want to establish a captive of their own. These are sometimes called divided asset companies or…

1974 – Suit Leasing Scheme

28 August 2018

In 1974 the UK’s top marginal tax rate of 83% applied to incomes over £20,000 (equivalent to £200,000 in 2018). In addition, passive investment income was hit with a 15% investment income surcharge which took the top rate to 98%. In 1974 750,000 people were in the 83% plus tax bracket. During this time senior…

Offshore Trusts

23 August 2018

  Trusts involve a settlor transferring (or ‘settling’) assets (i.e. the ‘trust property’) on the trustees. The trustees manage the assets for the benefit of a person, class or persons (the ‘beneficiaries’). An offshore trust is simply a conventional trust that is formed under the laws of an offshore jurisdiction. Most offshore jurisdictions have sophisticated…

Special Limited Partnership

21 August 2018

The Luxembourg special limited partnership (SLP) is a highly tax efficient investment vehicle that offers a high degree of contractual flexibility and cost efficiency (as the fundraising and investment structuring is in one jurisdiction). The SLP is exempt from income and wealth taxes and is only subject to an annual 0.01% subscription tax (which is…

"You’d be stupid not to try to cut your tax bill and those that don’t are stupid in business"

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