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29/07 | by Kitty Miv, Editor - During a year in which most banks saw recovery from the dark days of 2008, European 'offshore' banks suffered from a flight of capital to Hong Kong and Singapore. The McKinsey figures are borne out by reports from Jersey that less 'retention' (withholding) tax was garnered under the EU's Savings Tax Directive (STD) in 2009 than in 2008. This doesn't betoken immediate problems for Jersey and Guernsey, both of which in fact reported increased banking assets in 2009, but it should give pause to the EU legislators who are systematically damaging the region's banking sector. Continued, below

US To Close Foreign Tax Credit Loopholes
Last updated 4 hours ago | Friday, July 30, 2010
A package of legislative proposals designed to tighten US foreign tax credit rules has been introduced in the House of Representatives as part of a bill to extend certain Recovery Act provisions.
Vodafone Denies Tax Claim
Last updated 3 hours ago | Friday, July 30, 2010 The UK’s delegation to India, headed by Prime Minister, David Cameron, aims to bring the countries' relationship to a new level; but telecom giant Vodaphone, one of the UK’s major investors in India, remains embroiled in an unresolved USD2bn tax dispute.
UK Tax Credits To Go
Last updated 4 hours ago | Friday, July 30, 2010 Iain Duncan-Smith, the Secretary of State for Work and Pensions in the UK coalition government, is expected to formally unveil today (July 30) plans for a radical overhaul of the benefits system which could see low income tax credits swept aside in favour of a benefits model which provides more incentives for people to move into employment.
IRS Criticized By Treasury Watchdog Over Liens
Last updated 6 hours ago | Friday, July 30, 2010 A new report released by the United States Treasury Inspector General for Tax Administration says that the Internal Revenue Service has not always followed statutory requirements regarding the timely notification of taxpayers when liens are filed against them.


Lowtax Network Comment System

To ask a question or if you have an opinion you want to share: start a new thread, or reply to a thread below:


Topic: Bahamas
UK LLP: (1) what is its
I want to form a UK LLP with 2 non-UK company partners (90% Malta and 10% Switzerland). All decisions about the UK LLP will be taken in Malta (not the UK and not Switzerland). The fact that the LLP will be a UK one is for UK prestige and to avoid any perceived tax haven "taint".

The UK LLP will have a UK address, but only as a convenience - no significant activity will take place there, other than to accept formal documents.

The UK LLP will sell software on a rental basis wholly to clients outside the UK. Clients will "rent" the software which will physically sit on servers in France and Switzlerand. In other words the UK LLP has foreign source income and foreign owners, so no UK taxes involved.

My questions is: I understand (wrongly?) that the EU VAT registration must take place in the jurisdiction of the "permanent establishment" of the business.

Where is the formal "permanent establishment" for a UK LLP (specifically, "my LLP")? UK, Malta, or (heaven forbid) where the servers are based - i.e. France & Switzerland?

Where can the UK LLP register for VAT? The UK? Malta?

Apologies for the long question! Any help & advice appreciated.
 DH
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Topic: Bahamas
Seychelles IBC - can it pay a salary free of Seychelles income tax and scoial security contributions?
I have a Seychelles IBC managed and controlled from a jurisdicition outside Seychelles. I live in Switzerland. No business is transacted in, from, or with the Seychelles. I never visit Seychelles.

Can a Seychelles IBC pay me a salary for my services without having to account to the Seychelles government for Seychelles income taxes and social security contributions?

"Nobody would know", whilst true, is not a valid answer!  CH resident
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Topic: Lowtax.net General
Overtaxed US Citizen wants suggestion
I'd like to be able to direct about $700K a month to HSBC in an offshore account and then block the funds for different investments, letting the profits accumulate at low tax till I bring the funds into the US. I am told that no matter where I place it I'll have to deal with the close to 50% tax here in the US. I've been thinking of the Bahamas- any top 25 world bank would be OK, any suggestions?  
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Topic: Gibraltar
Gibraltar-Offshore or onshore?
 
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Topic: Hong Kong
Hong Tax-US Resident
I closing a transaction in Hong Kong. I live in the USA. We want to assign the transaction/contract to a Hong Kong Corporation that we (US Citizens) ouwn. I understant there is no corporate tax, dividend tax, capital gain tax in Hong. If we leave the money in Hong Kong are we taxed in the US? If we bring monies to the USA, we would tax at the applicable rate. Is this correct???  
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Topic: Singapore
Ireland tax traty with singapore-pending
Does anyone know if there is a pending tax treaty for investment money coming from singapore to Ireland  
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Topic: Mauritius
New company setup advise
I am a UK resident and I want to setup a company that manufactures physical goods in Korea and sells/distributes them in Western and Eastern Europe and North America. The turnover would be in usd 1-2m region annually with profit at ~40%. Can this type of activity be classified as e-commerce (if we setup website)? What is the best place to setup such a company as well as offshore bank account for the partners so that the dividend is not repatriated to the UK.  Kristina
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Topic: Singapore
Singapore Tax
We are a full service accounting company located at Beach Road, Singapore. For years, we have been providing corporate secretarial, bookkeeping, accounting, payroll, taxation, and many other accounting services to a wide range of clients, including both businesses and individuals throughout the island. We have developed a reputation for professional excellence through the high quality of services we perform for our clients.

We provide Corporate Secretarial, Bookkeeping, Accounting & Payroll and Tax Services to our clients.
As a one-stop solution provider for companies' professional outsourcing needs, we seek to bring greater value propositions to our clients, and create synergistic benefits for all professional outsourcing needs.

admin@bestarservices.com.sg
http://www.bestarservices.com.sg  Angus
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Topic: Hong Kong
intermediate services : cost in Hong Kong
My supply chain is simple. I buy goods in mainland China to sell them in the EU. Hong Kong is tax friendly and if I appoint a Hong Kong commissionnaire (subsidiary group member) to buy goods on my behalf, I of course have to grant an at arm's length remuneration. What is the usual commission rate (in percentages of value of acquired goods) owed to a Hong Kong based low risk bearing intermediate ?  quartz
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Topic: Lowtax.net General
France, UK accepting business from Seychelles
I have a question regarding Seychelles. I am a contractor and live in the UK and have setup an offshore IBC in Seychelles. I work across Europe (France, Netherlands and UK) and the company that has hired me in Paris told me that because my company is in the Seychelles and as France does not have a tax treaty with Seychelles they need to withhold 33% tax as that is the law. This basically means that I only get 66% out of 100%. Does this apply to all countries that do not have tax treaties with Seychelles? If that is the case, Seychelles will not be an interesting country as an offshore country. Does any off you have a better structure to minimize tax paid? Any feedback highly appreciated.
 NT
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Topic: Lowtax.net General
Seychelles? HK? Where should I offshore my consultancy for my international client work?
I have a LLC set up in Wyoming that I (and two other equal partners) run all of our marketing advisory and international expansion consulting work through. We originally intended to help small, but highly ambitious American companies expand overseas either through JVs or simply new distributors/promoters. Recently, we've found ourselves get more and more business bringing foreign companies and brands from overseas back to the US. We are beginning to get paid in RMB, HKD, CHF, GBP, JPY, and EUR as much as we are paid USD. We're wanting to focus more and more on higher-paying (and more exotic) overseas clients.

Any suggestions, insights, or gut feelings (with reasoning) on setting up an IBC to serve our legitimate non-US billable business?

Again, we do a lot of work in China, HK, and Europe. We're wondering if Seychelles is really that easy and inexpensive to set up and ultra-efficient in the long term or if we're going to create more headaches than it's worth.

Ultimately any IBC we set up will be owned by (three) American citizens (we have no objections to paying taxes on any eventual payouts), but would appreciate the opportunity to be more tax efficient if we can legally route more of our legitimate expenses associated handling international clients to an offshore entity.

What issues should I consider? I figure the community has been in my exact situation many times before. Any collective wisdom? A diversity in opinion/experiences is appreciated, as well.

Am I'm over thinking this?

Many thanks, YL.  Yvon Lacombe
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Topic: British Virgin Islands
checking for a business name
Where can I find out whether or not if a company that I want to register in BVI has already been registered (or the name already taken)? All help is greatly appreciated!  ssm
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Topic: Cyprus
how to choose an offshore corporation
Hello, there is a situation. I have to reduce income taxes for export production from Russia to USA. As I guess the best way is to use offshore. But which country to choose for this (e.g. Cyprus or Panama, or other). Thanks :)  Monika
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Topic: Seychelles
Overtaxed Aussie
I own a design firm in Australia - All my clients are Australian based and they just simply would not deal with a cyprus/panama company. Basically I make around 250k a year and see a very large chunk of this go to the government to be squandered on free flights for politicians and dole bludgers.

I am currently setting up an internet site selling bits and pieces. I plan to start a bank account in Hong Kong (under a Seychelles based IBC )

I have looked at banks over there and found one that I like (1% visa fee on atm withdrawals as well as reasonable priced money transfers to china (my supplier))

I have been reading the ATO's blog that they monitor the use of ATM cards aswell as EVERY wire transfer going out (Its hard to believe as they would need 500000 employees)

Basically my question is this. Is there any way to lessen my tax burden in Australia with an offshore solution. Say I buy an IBC in Seychelles is there anything stopping me from opening a bank account then shut the IBC down saving me 500-1000 dollars a year?

I have looked at dumping money into super however this still has kevin rudds finger in the pie at 15% on earnings each and every year (You cannot get ahead that way.)


 Overtaxed Aussie
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Topic: Lowtax.net General
investment advice singapore or hong kong companies
can anyone recommend an investment co in singapore or hong kong that caters for persons of low to medium wealth as I should like to invest modestly in China and have someone manage a small portfolio  small investor
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Topic: Romania
What is the best solution for a Romania based company?
What is the best solution for a Romania based company with 2 associates: 1 romanian and 1 french. The activity of the company is worldwide and we are looking for an optim financial solution to simplify the tax system of our company.
The activity of the company is management and consulting services.  
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Topic: Madeira
Best way to purchase property in Madeira
HI, my husband and I have purchased a piece of land on which we would like to build a holiday home in Madeira. We are South African residents. We do not intend to sell the property in the future and would like our children and grandchildren to benefit form the use. We would like to know which would be the best option in terms of registering the property for the lowest costs. Should we register it in our personal names or in a Company (non trading) or a trust? Also from an asset protection point of view, which would be the best route?  Charmaine
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Topic: Luxembourg
Canada resident
Hi, I might get 300000 EUR from the sale of a building in France and I'm thinking to invest it into some kind of stockmarket fund, in a "civilized" region like Europe. But I do not want it to be based in Canada or France. Where should I invest it? I want to minimize the taxes and I bet in France they are too high. In Luxembourg? in Switzerland? In the UK? In Andorra? Spain, Italy, Belgium, Netherlands, Lichenstein, Austria... I heard good things about Austria or Luxembourg.
Could you advise?
Thank you
Roger  Roger
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Topic: Guernsey
Pay Day Loans
Hi there,
I am looking for some advice. I am an Australian who lives in the U.K. Without getting to much into detail about the tax situation, what I would like to know is can I start a pay day loans business in Guernsey and lend to people in the U.K? This would prove beneficial in the long run for me to operate my company outside the U.K. I appreciate that I would be generating business in the U.K but as it would solely be based online does that mean that the company would get taxed at the Guernsey rates.
Conversely, could I just lend my other company in the U.K money at a high rate so it only breaks even and therefore it would be the Guernsey company that makes the profit.
Any help or pointing in the right direction would be helpful. Regards,
Neil Spence  Neil Spence
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Topic: Lowtax.net General
Withholding taxes(WHT) in Botswana
Apart from the normal interest on loans, royalties, management, consulting and service fees, are there any other transactions between companies within a multinational group (related party transactions) that are deemed to attract WHT in Botswana?  KG
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"The fact that you've aged 10 years in the last 6 months isn't accelerated depreciation, it's accelerated decrepidation."
CARTOON ARCHIVE

Continued, from above. The STD was the first of the major disincentives put in the way of capital formation in Europe; now that the powers that be in Brussels have belatedly realized this, they are trying, unsuccessfully of course, to persuade the rest of the world to join in their madcap scheme.

But not content with driving away private capital, the pea-brained 'communautaire' EU establishment is now trying to drive away the banks themselves with rafts of restrictive legislation and punitive taxation regimes. And of course for the last ten years the high-taxing member states of the EU have been engaged on a campaign to throttle the low-tax jurisdictions which had been acting as a safety-valve for discontented HINWIs.

What in their unwisdom they don't realize is that, while countries are fixed in position, capital, banks and depositors are all of them mobile. The private wealth sector is like a super-tanker, taking a very long time to change direction, but unstoppable once it has done so.

There is quite a generational effect going on here, as well. After the second world war much wealth was sitting in Switzerland because for rich Europeans that country had for fifty years been the only stable and safe place for them to keep their money. But Switzerland has, perhaps foolishly, or perhaps unavoidably, allowed the EU to nibble away at its independence and its banking secrecy.

Now, the rich young children of those conservative European bankers and industrialists have a wider vision, and for them independent city states like Singapore and (pace China) Hong Kong have a greater allure than the fading Helvetic Confederation.

As for the banks themselves, they all opened branches in Hong Kong decades ago, so they are ready and waiting for the influx. It's nothing to them that assets take wing from their Andorran and Manx branches and alight on the Peak. It takes just a microsecond nowadays.

Ciao, Kitty.

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29/07 New Lowtax Editor Column, by Kitty Miv
28/07 New PBTG Editor Column, Caroline, PBTG editor
27/07 UK Launches Raft Of Tax Consultations, Tax-News.com
26/07 Fat Tax On The Menu , Jeremy Hetherington-Gore blog entry
23/07 Sarkozy Seeks 'Fiscal Convergence' With Germany, Tax-News.com
20/07 Singapore Base For Tuvalu OIFC, Tax-News.com
19/07 Expats Turn Backs On US Taxes, Tax-News.com
16/07 Congress Approves US Financial Reform Bill, Tax-News.com
15/07 New Lowtax Editor Column, by Kitty Miv
15/07 St Vincent & The Grenadines, Investors Offshore special feature
13/07 Tax-News.com Jersey Review 2010-2011
12/07 Goodbye To All That, Jeremy Hetherington-Gore blog entry
09/07 Antigua Pursuing Trade Sanctions Against US, Tax-News.com
08/07 New Lowtax Editor Column, by Kitty Miv
06/07 Hong Kong Full PBTG Guide, added to Personal Business Tax Guide
05/07 Australian Mining Tax Agreement Reached, Tax-News.com
02/07 Online Trading For Expats, Investors Offshore special feature
29/06 EC To Extend Common System Of VAT, Tax-News.com
28/06 Lowtax Dubai, annual update
25/06 Jersey Considers Tax Future, Tax-News.com
22/06 VAT Hiked In UK Emergency Budget, Tax-News.com
21/06 Steady Progress In TPP Negotiations, Tax-News.com
18/06 Singapore - Another Hong Kong?, Investors Offshore special feature
15/06 Swiss Parliament Approves UBS Agreement, Tax-News.com
14/06 Ethical Moonshine, Penelope Wise blog entry
11/06 Germany Purchases Stolen Tax Data Disc, Tax-News.com
08/06 Dubai Full PBTG Guide, added to Personal Business Tax Guide
07/06 G-20 Shelves Global Bank Tax, Tax-News.com
04/06 Lowtax Panama, annual update
01/06 Lowtax Luxembourg, annual update
31/05 OECD And EU Strengthen Tax Cooperation, Tax-News.com
28/05 Lowtax Guernsey, annual update
25/05 Lowtax Jersey, annual update
24/05 Lithuania Summary PBTG Guide, added to Personal Business Tax Guide
21/05 Lowtax Liechtenstein, annual update
18/05 Latvia Summary PBTG Guide, added to Personal Business Tax Guide
17/05 Offshore And The Euro, Jeremy Hetherington-Gore blog entry
14/05 IO Focus: Barbados, Investors Offshore special feature
03/03 Personal Business Tax Guide, PBTG, has launched!
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