Lowtax Jurisdictions
LEGAL SERVICES; PANAMANIAN CORPORATIONS, PRIVATE INTEREST FOUNDATIONS, IBC FROM BVI, BELIZE,CYPRUS,COSTA RICA, BAHAMAS,SEYCHELLES, ANGUILLA, BARBADOS, AND OTHERS, BANKING LAW, ASSETS PROTECTION AND ADMINISTRATION, INTELLECTUAL PROPERTY, DATA PROTECTION.
miércoles, 8 de febrero de 2012
Liechtenstein, UK Seal Tax Treaty
by Ulrika Lomas, Tax-News.com, Brussels
08 February 2012
During a recent working visit to Vaduz by Dave Hartnett, Permanent Secretary for Tax at HM Revenue and Customs (HMRC), Liechtenstein and the UK initialled a landmark comprehensive bilateral Income Tax Treaty, and extended the unique Liechtenstein Disclosure Facility.During the course of the visit, Katja Gey, Director of Liechtenstein's Office of International Financial Affairs, and Hartnett initialled a first-ever comprehensive convention on taxation of income and capital between Liechtenstein and the UK, based on the 2010 Organization for Economic Cooperation and Development (OECD) Model.
According to the Liechtenstein government, the agreement results from two years of talks and negotiations and evidences the long-term commitment of the parties to tax cooperation, clarity and compliance, and reflects and balances the interests and needs of both parties.
The Liechtenstein government stated: “Importantly, the treaty will encourage an increase in cross-border business between Liechtenstein and the UK, affording Liechtenstein tax residents a number of important UK tax advantages and clarity in their UK tax treatment.”
“Such benefits will also be available to qualifying Liechtenstein corporate entities, trusts, trust enterprises, foundations, establishments, and investment funds. The treaty, which will now go through formal procedures of signing and ratification, is expected to come into force from January 1, 2013.”
Commenting on the agreement, Liechtenstein Prime Minister Klaus Tschütscher emphasized that: "Once again we prove that we are a reliable partner. Our industry and our financial centre will be linked to the largest tax treaty network in the world. This treaty provides clarity and stability of tax treatment”.
In addition to concluding negotiations on the treaty, both parties agreed to an extension of the Memorandum of Understanding Relating to Cooperation in Tax Matters of August 11, 2009 (MoU), including the unique and favourable terms of the LDF for an additional year.
The government stresses that this will make voluntary disclosure of past due UK tax liabilities possible for UK taxpayers with non-UK assets who establish a meaningful connection to Liechtenstein until April 5, 2016.
Gey, who has led the efforts in Liechtenstein on the treaty and the MoU, stated that:
"We are delighted to have agreed a full tax treaty with the UK, evidencing Liechtenstein's genuine commitment to tax compliance and the UK's assistance to our work in ensuring the long term success of the Liechtenstein financial centre. The treaty will offer significant new clarity in how Liechtenstein residents are taxed when investing and doing business with the UK, and will encourage the use of Liechtenstein entities, bringing new business to both Liechtenstein and the UK."
"The extension of the favourable terms of the LDF for an additional year is of enormous value to UK taxpayers worldwide, and reflects our commitment to a win-win-win approach under which the interests of clients of Liechtenstein financial intermediaries are always, for us, at the forefront while we also seek to ensure both the development of our financial centre and the preservation of the legitimate tax collecting interests of the UK, our close partner in these arrangements. The additional year of application of the LDF will benefit all parties and, I am pleased to note, particularly UK taxpayers who maintain the requisite relationship with our financial centre."
During HMRC's visit to Liechtenstein, the Office for International Financial Affairs led meetings between HMRC and representatives and members of the Liechtenstein Association of Professional Trustees, the Liechtenstein Bankers Association and the Liechtenstein Insurance Association.
The parties also reviewed recently agreed procedures under which compliant UK clients of Liechtenstein financial intermediaries may certify their UK tax compliance, including through self-certification, ensuring that the process avoids unnecessary costs or delay.
Following the visit, Prime Minister Tschütscher stated that: “We are enabling attractive tax and financial positions through facilitated and transparent framework requirements, and will react cooperatively with professional partners to our clients' needs. It is especially clear to us, that those businesses with undeclared capital have no future".
martes, 7 de febrero de 2012
TRUST VS. FOUNDATION
TRUST VS FOUNDATION
Twitter - @panamalowtax
Historically a trust as a structure has been mainly used in common-law countries and still not always understood and appreciated by representatives of civil-law countries. They prefer to use foundations for different purposes as an alternative to Trust. The main difference between these structures is in the right to control them. A Trust must be fully controlled and managed by a trustee form the best interests of the Trust beneficiaries; once the assets are transferred to a Trust, a settlor no longer has any control over them. Every Foundation, in turn, has a Protector, who is generally a person connected to a Foundation founder (settlor) and therefore may have a certain influence on the development process and management of a Foundation. Moreover, a Foundation is allowed to have a bank account, in contrast to a Trust, where a trustee fully operates the capital. A Foundation is a separated legal entity and generally names one or more beneficiary for a socially responsible purpose, such as a charitable organization, education of children, etc. , Its owner its not registered in any public registries for the simple reason that a Foundation does not have an owner. Once such a Foundation owns shares of a particular company, such a corporate entity, becomes fully confidential as well. Foundations are effective structures for inheritance and holistic tax optimization purpose. Therefore, a Foundation when properly structured and incorporated in the appropriate jurisdiction for any special need and objectives can provide you the benefits of a commercial company, not-non-profit organization and trust. It will ensure confidentiality as well as effective assets protection and management opportunities.
Twitter - @panamalowtax
jueves, 12 de enero de 2012
READY MADE BVI OFFSHORE COMPANIES
BVI ready made offshore companies are availables as follows:
january 2012
september 2011
december 2011
www.laglex.com
gabriel.aguilar@laglex.com
january 2012
september 2011
december 2011
www.laglex.com
gabriel.aguilar@laglex.com
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