Only in the event that the income will be recognized by the income of the English company, it can apply for use of contracts on avoidance of the double taxation. Certainly, application of contracts on avoidance of the double taxation by the company submitting «sleeping reports» - dormant accounts is impossible. Use of tax contracts in holding schemes is possible.
Other developed states have the similar requirements necessary for application of tax agreements and reception of the certificate on a site.
Possibly most suitable jurisdiction for application of tax agreements on avoidance of the double taxation is now republic Cyprus. The certificate about tax rezidentstve (tax residence certificate), stands out the Ministry of Finance at any time after company registration. Conditions of reception of the certificate - presence of local directors - residents of Cyprus.
Summing up, it is possible to formulate is short high lights which need to be considered at a choice of jurisdiction during the international tax planning:
1. A tax mode in the registration country.
Taxation conditions depend concrete jurisdiction. Classical offshore jurisdictions (Panama, the British Virgin Islands, Seychelles, Belize and others) provide tax exemption or establish the zero taxation for the companies.
In other states the profit tax of the companies is provided: Cyprus (10 %), Great Britain (from 20 to 30 %), New Zealand (33 %).
The exception makes Hong Kong which is not offshore jurisdiction, but provides absence of the taxation for the companies conducting activity outside of Hong Kong. It does Hong Kong, perhaps, by one of the most attractive jurisdiction for company registration.
2. Application of agreements on avoidance of the double taxation.
"The classical" offshore countries seldom have the concluded Conventions/agreements on avoidance of the double taxation which can be used by optimization of payments of incomes of non-resident structures.
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