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 (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…
Average weekly pay: $1,473 Employment size: 14,100 Future growth: Stable Skill level Bachelor degree or higher …
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…
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…
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…
Objectives: Frankie is an aircraft engineer working for Qantas at the Sydney Airport. Frankie uses some of his own specialist tools to perform his job every day but doesn’t leave them at the workplace overnight due to recent thefts. Frankie wants to protect his valuable tools and save tax. Facts: …
Nugan Hand Bank was an infamous Australian merchant bank that was involved in drug smuggling, arranging weapons deals, providing a front for the United States CIA, money laundering and tax evasion schemes (including the Bottom of the Harbour). Nugan Hand Ltd was founded in Sydney in 1973 by Australian lawyer Francis John ‘Frank’ Nugan and…
If your business has a turnover greater than $2 million then to qualify for the small business CGT concessions (and potentially pay no tax on your business sale) you need to pass the $6 million net assets test. The net value of CGT assets includes assets owned by you, any entities ‘connected with’ you, any…
Hong Kong, the British Virgin Islands, and Panama have the largest numbers of registered International Business Companies (IBCs). Jointly these three countries are home to over 1.5 million IBCs. The main difference between offshore companies and IBCs is that IBCs are not taxable in the country of incorporation as long as they don’t engage in…
"You’d be stupid not to try to cut your tax bill and those that don’t are stupid in business"
- Bono: U2