When choosing a tax haven, its location, proximity and accessibility can be a deal breaker. Generally, tax havens close to major financial centres, where you live, or do business will be preferred. The Cayman Islands, for example, is only 725 km from Miami (Florida) and can be accessed by an 80-minute flight. Delaware, for example,…
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English law is the preferred governing law for business transactions worldwide, as English law has a well-known, well-developed and reputable jurisprudence. In addition, because of the British Empire, English law is widespread as its former colonies have modelled their legal systems closely on English law. UK tax havens include the 14 British Overseas Territories (including…
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There are 19 different reasons to use a tax haven, some legal, and some illegal. No doubt, there are many more, so when choosing a tax haven, we need to firstly look at our objectives – what are we really trying to achieve? Some of the objectives will be complementary (like saving tax and privacy),…
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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…
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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…
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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…
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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…
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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…
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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…
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Multinational businesses often finance their Australian business investments with large amounts of overseas debt instead of equity as it is more tax effective for the following reasons: Subject to compliance with the thin capitalisation rules the interest expense is deductible against the Australian business’s profits. Each $1.00 of interest expense saves $0.275 or $0.30 in…
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"You’d be stupid not to try to cut your tax bill and those that don’t are stupid in business"
- Bono: U2