Global offshore tax guide . Volume 1

목차 (Table of Contents)

• CONTENTS
• BASIC OFFSHORE ACTIVITIES = 16
• OFFSHORE BUSINESS AND INVESTMENT ACTIVITIES: BASIC DEFINITIONS = 16
• THE LIST OF MAJOR OFFSHORE JURUSDICTIONS = 16
• INVESTING OFFSHORE: BASIC INFORMATION = 21
• MAJOR FORMS OF OFFSHORE INVESTMENTS = 25
• Banking = 25
• Fund Investment = 26
• Private Funds = 27
• Public Funds = 28
• Offshore Fund Investments = 28
• Offshore Equity Investment = 29
• Choosing an Investment Base = 29
• Offshore Equity, Investment = 29
• PENSION INVESTMENTS = 32
• Offshore Pensions Investment = 33
• Where To Make Pensions Investments Offshore = 34
• INTERNATIONAL OFFSHORE BUSINESS COMPANIES = 36
• International Business Companies Formation Strategy = 36
• STRATEGY A = 36
• STRATEGY B = 37
• STRATEGY C = 37
• FREQUENTLY ASKED QUESTIONS = 38
• FORMS OF INTERNATIONAL OFFSHORE COMPANIES = 39
• Trading Corporations = 39
• Investment Corporations = 39
• Holding Corporations = 40
• Treasuty Coiporations = 40
• Patent, Copyright & Royalty Corporations = 40
• Consulting Corporations = 40
• Real Property Corporations = 40
• Captive Insurance Corporations = 41
• Private Banking Corporations = 41
• INTERNATIONAL BUSINESS COMPANIES ("IBCs") AND TAXATION = 41
• EXEMPTION FROM TAX AND STAMP DUTY = 41
• CONFIDENTIALITY = 41
• INNOVATIVE CORPORATE FEATURES = 42
• MINIMAL GOVERNMENT FILING FEES = 42
• MOBILITY& SECURITY OF INVESTMENT = 42
• FLEXIBLE ADMINISTRATIVE FEATURES = 42
• USES OF AN INTERNATIONAL BUSINESS COMPANY = 43
• INTERNATIONAL BUSINESS COMPANIES OFFSHORE REGISTARATION = 43
• REGULATIONS FOR ESTABLISHING AN OFFSHORE COMPANY = 45
• Introduction to IBCs = 45
• International Business Companies = 46
• Types of Offshore Busienss Companies = 46
• Documents = 47
• Other Parties = 49
• Choice of Governing Law = 51
• Administration for IBCs = 51
• Offshore Business Company Purposes = 53
• TAX HAVENS = 55
• USE OF A TAX HAVEN = 56
• OFFSHORE & TAXES = 56
• QUALIFIED RETIREMENT PLAN (QRP) = 56
• MUNICIPAL BONDS = 57
• ANNUITIES = 57
• MUTUAL FUND ANNUITIES = 57
• OFFSHORE TAX PROTECTION. = 58
• Tax Reform = 58
• Reviewing the options = 59
• Offshore tax advantage = 60
• SELECTES QUESTIONS AND ANSWERS ON OFFSHORE TAXATION = 61
• OFFSHORE COUNTRIES AND JURISDICTIONS : BASIC AND TAX REGULATIONS = 70
• ANDORRA = 70
• OFFSHORE ANT TAXES = 70
• Forms of Offshore Operation = 70
• Fees Payable by Companies = 70
• Taxation of Foreign Employees of Offshore Operations = 70
• Exchange Control = 70
• Offshore Activities in Andorra = 70
• Employment and Residence = 71
• CORPORATE TAXES = 71
• Business License Fees = 71
• Payroll Taxes = 72
• Property Taxes = 72
• PERSONAL TAXES = 72
• Residence and Liability for Taxation = 72
• Payroll Taxes = 72
• Municipal Taxes = 73
• FORMING A COMPANY IN ANDORRA = 73
• BASIC CONTACTS = 75
• ANGUILLA = 75
• Taxation & Exchange Control = 75
• Taxation = 75
• Exchange Control = 76
• Corporate Structures = 76
• ARUBA = 76
• TAX REGIME = 76
• Rates of Profits Tax = 76
• Calculation of Taxable Base = 77
• Withholding Tax = 78
• Real Estate Taxes = 78
• BUSINESS TAXES = 78
• Taxation of Foreign Employees of Offshore Operations = 80
• TAX TREATIES = 81
• The Netherlands Tax Treaty = 81
• Other International Agreements = 81
• SELECTED BUSINESS CONTACTS = 82
• Banking Services, Investment and Trust Management = 82
• Accounting, Taxes and Auditing = 83
• BAHAMAS = 83
• COMPANY TAXES = 83
• Business License Fees = 83
• Payroll Taxes = 84
• Stamp Duties = 84
• PERSONAL TAXES = 84
• Residence and Liability for Taxation = 84
• Payroll Taxes = 85
• Stamp Duties = 85
• Real Estate Tax = 85
• Double Tax Treaties = 86
• Other International Agreements = 86
• BARBADOS = 86
• OFFSHORE AND TAX CLIMATE = 86
• Forms of Offshore Operation = 87
• Tax Treatment of Offshore Operations = 87
• Taxation of Foreign Employees of Offshore Operations = 89
• Exchange Control = 89
• Offshore Activities = 90
• Employment and Residence = 90
• CORPORATE TAXATION = 90
• Corporation Tax = 90
• Corporation Tax Rules = 90
• Branch or Subsidiary = 91
• Calculation of Taxable Base = 91
• Filing Requirements and Payment of Tax = 91
• Withholding Tax = 92
• Land Tax = 92
• Stamp Duty = 92
• Taxation of Foreign Employees of Offshore Operations = 95
• PERSONAL TAXES = 95
• Residence and Taxation = 95
• Income Tax = 95
• Social Security Taxes = 96
• Land Tax = 96
• Stamp Duty = 96
• Property Transfer Tax = 96
• Customs Duties = 97
• Double-Tax Treaties = 97
• Tax-Sparing Provisions = 97
• Table of Treaty Rates = 98
• Other Intrnational Agreements = 98
• SELECTED BUSINESS CONTACTS = 99
• BERMUDA = 101
• OFFSHORE BUSINESS CLIMATE AND ACTIVITIES = 101
• Investment Fund Management = 103
• TAXATION = 110
• CORPORATE TAXATION = 110
• Payroll Taxes = 110
• Social Insurance = 110
• Filing Requirements and Payment of Tax = 111
• Health Insurance = 111
• PERSONAL TAXATION = 111
• Residence and Liability for Taxation = 111
• Payroll Taxes = 111
• Miscellaneous Taxes and Duties = 112
• Customs Duties = 112
• OFFSHORE TAXATION = 112
• Tax Treatment of Offshore Operations = 112
• Taxation of Foreign Employees of Offshore Operations = 112
• Exchange Control = 113
• Offshore Activities in Bermuda = 113
• Employment and Residence = 113
• SELECTED BUSINESS CONTACTS = 114
• Offshore Company & Ship Registration = 115
• Investment Fund & Trust Management = 115
• Law Firms = 116
• Tax Planning = 116
• Trust Management = 117
• CAYMAN ISLANDS = 117
• OFFSHORE BUSINESS CLIMATE & ACTIVITY = 117
• Cayman Islands Stock Exchange = 117
• Entry and Residence = 117
• CORPORATE TAXE = 123
• PERSONAL TAXES = 123
• DOUBLE TAX TREATIES = 124
• SELECTED BUSINESS CONTACTS = 124
• COOK ISLANDS = 127
• Cook Islands Inclusion on FATF Blacklist = 127
• Tax Treatment of Offshore Operations = 127
• Taxation of Foreign Employees of Offshore Operations = 127
• Employment and Residence = 127
• CORPORATE TAXES = 128
• PERSONAL TAXES = 128
• Income Tax = 128
• DOUBLE TAX TREATIES = 128
• Provision of Information = 129
• International Agreements = 129
• SELECTED BUSINESS CONTACTS = 130
• COSTA RICA = 131
• OFFHORE ACTIVITY = 131
• Entry and Residence = 131
• Business Environment = 132
• Import of Foreign Capital = 132
• Foreign Investment Incentives = 133
• Free Trade Zone = 133
• Forms of Offshore Operation = 134
• Exchange Control = 135
• Tax Treatment of Offshore Operations = 136
• Taxation of Foreign Employees of Offshore Operations = 137
• CORPORATE TAXES = 137
• Scope of Income Tax = 137
• Rates of Income Tax = 137
• Calculation of Taxable Base = 138
• Filing Requirements and Payment of Tax = 138
• Withholding Tax = 138
• Stamp Duties = 140
• Social Security Taxes = 140
• PERSONAL TAXES = 140
• Residence and Liability for Taxation = 140
• Income Tax = 141
• Social Security Taxes = 142
• Capital Transfer Tax = 142
• Value Added Tax = 143
• Double Tax Treaties = 143
• Other International Agreements = 143
• SELECTED BUSINESS CONTACTS = 143
• CYPRUS = 145
• OFFSHORE REGIME = 145
• Forms of Offshore Operation = 145
• Tax Treatment of Offshore Operations = 146
• Taxation of Foreign Employees of Offshore Operations = 147
• Exchange Control = 147
• Offshore Activities = 147
• Employment & Residence = 147
• CORPORATE TAXES 1 = 148
• Corporation Tax = 148
• Corporation Tax Rates = 149
• Branch or Subsidiary? = 149
• Calculation of Taxable Base = 149
• Filing Requirements and Payment of Tax = 150
• Withholding Tax = 150
• PERSONAL TAXES = 150
• Residence and Liability for Taxation = 150
• Income Tax = 151
• Capital Gains Tax = 152
• Estate Duty = 152
• Real Estate Taxes = 152
• Customs Duties = 153
• Business Environment = 153
• Larnaca Industrial Free Zone = 154
• Import of Foreign Capital = 154
• Investments by Foreigners = 154
• Cyprus Stock Exchange (CSE) = 155
• Entry & Residence = 155
• Trade Marketing & Distribution = 156
• Licensing, Royalties & Franchising = 157
• Financial Holding & Investment Activities = 157
• Offshore Banking Unit = 157
• Subsidiaries of foreign banks = 158
• SELECTED BUSINESS CONTACTS = 160
• DUBAI = 161
• OFSSHORE AND BUSINESS CLIMATE = 161
• Forms of Offshore Operation = 161
• Tax Treatment of Offshore Operations = 162
• Taxation of Foreign Employees of Offshore Operations = 163
• Exchange Control = 163
• Employment & Residence = 163
• CORPORATE TAXES = 163
• Customs Duties = 163
• Business Properties Tax = 164
• PERSONAL TAXES = 164
• DOUBLE TAX TREATIES = 164
• Investments by Foreigners = 165
• OFFSHORE BUSINESS ACTIVITY = 165
• SELECTED BUSINESS CONTACTS = 170
• Ministries & Departments = 170
• DUBAI BUSINESS REPRESENTATIONS = 171
• North America - East and Central = 171
• East Africa = 171
• South Africa = 171
• UK & Ireland = 171
• France = 171
• Far East = 172
• Germany = 172
• Japan = 172
• Nordic Countries = 172
• Italy = 172
• Russia, CIS & Baltic States = 172
• GIBRALTAR = 173
• TAXATION = 173
• CORPORATE TAXES = 173
• Scope Of Corporation Tax = 173
• Corporate Tax Rules = 174
• Calculation of Taxable Base = 174
• Taxation of Trusts = 175
• Filing Requirements and Payment of Tax = 175
• Withholding Tax = 175
• PERSONAL TAXES = 175
• Residence and Liability for Taxation = 175
• Income Tax = 176
• Social Insurance = 177
• Double Taxation Treaties = 177
• SELECTED BUSINESS CONTACTS = 178
• GUERNSEY = 180
• OFFSHORE ACTIVITY = 180
• SELECTED BUSINESS CONTACTS = 182
• Offshore Company & Ship Registration = 182
• Banking Services & Asset Management = 184
• Captive Insurance = 185
• Law Firms = 186
• Trust Management = 186
• HONG KONG = 189
• TAXATION SYSTEM = 189
• CORPORATE TAXES = 190
• Profits Tax = 190
• Profits Tax Rates = 191
• Calculation of Taxable Base = 192
• Profits Tax Deductible Allowances = 194
• Property Tax = 195
• Stamp Duty = 196
• Property Stamp Duty Anti-Avoidance Provisions = 197
• Stamp Duty Payable on Shares & Marketable Securities = 197
• Securities Transactions Exempted from Stamp Duty = 197
• Stamp Duty Payable on Bearer Instruments = 197
• Filing Requirements and Payment of Tax = 197
• Withholding Tax = 198
• PERSONAL TAXES = 198
• Salaries Tax = 198
• Estate Duty = 200
• Gifts Tax = 201
• Property Tax = 201
• Social Insurance = 202
• Stamp Duty = 202
• Immovable Property Stamp Duty Rates = 202
• Immoveable Property Stamp Duty Anti-Avoidance Provisions = 203
• Stamp Duty Payable on Shares & Marketable Securities = 203
• Securities Transactions Exempted from Stamp Duty = 203
• Stamp Duty Payable on Bearer Instruments = 204
• OFSHORE TAXES = 204
• Low-Tax Treatment Of Business Operations = 204
• Taxation Of Foreign Employees Of Business Operations = 206
• Exchange Control = 207
• Employment And Residence = 207
• Double Tax Treaties = 208
• SELECTED CONTACTS = 209
• IRELAND = 214
• BUSINESS CLIMATE AND OFFSHORE TAX REGIME = 214
• Forms of Low Tax Operation = 214
• The International Financial Services Centre = 214
• The Shannon Free Zone = 215
• The 10% 'Manufacturing Rate' of Tax = 216
• Non-Resident Companies = 217
• Taxation of Foreign and Non-Resident Employees = 218
• Exchange Control = 219
• Employment and Residence = 219
• CORPORATE TAXES = 219
• Scope of Corporation Tax = 219
• Corporate Tax Rates = 220
• Calculation of Taxable Base = 220
• Stamp Duty = 221
• Withholding Tax = 221
• PERSONAL TAXES = 221
• Residence and Liability for Taxation = 222
• Income Tax = 222
• Customs Duties = 223
• Double Tax Treaties = 223
• Treaties = 223
• SELECTED BUSINESS CONTACTS = 224
• Offshore Company Registration = 224
• Trust Management = 225
• JERSEY = 226
• OFFSHORE AND BUSINESS CLIAMTE = 226
• Forms of Offshore Operation = 226
• Tax Treatment of Offshore Operations = 226
• Taxation of Foreign Employees of Offshore Operations = 227
• Exchange Control = 228
• Offshore Activities = 228
• Employment and Residence = 228
• Corporate Taxation in Jersey = 228
• Income Tax = 228
• Income Tax Rates = 229
• Calculation of Taxable Base = 229
• Taxation of Trusts = 229
• Taxation of Partnerships = 230
• Filing Requirements and Payment of Tax = 230
• Withholding Tax = 230
• PERSONAL TAXES = 231
• Residence and Liability for Taxation = 231
• Income Tax = 231
• Customs Duties = 232
• Double Tax Treaties = 232
• SELECTED BUSINESS CONTACTS = 233
• Offshore Company and Ship Registration = 233
• Banking Services and Asset Management = 236
• Trust Management = 238
• Law Firms = 239
• LABUAN = 240
• OFFSHORE BUSINESS CLIAMTE = 240
• Offshore Operation = 241
• Tax Treatment of Offshore Operations = 241
• Tax-Efficient Structures Involving Labuan = 242
• Malaysian External Investment = 242
• Foreign Direct Investment in Malaysia and Korea = 243
• Offshore Tax Treatment Of Foreign Employees = 243
• Offshore Activities = 243
• Employment and Residence = 244
• CORPORATE TAXATION = 246
• Income Tax = 246
• Rates of Income Tax = 247
• Development Tax = 247
• Calculation of Taxable Base = 247
• Filing Requirements and Payment of Tax = 248
• Real Estate Gains Tax = 248
• Withholding Tax = 249
• PERSONAL TAXES = 249
• Residence and Liability for Taxation = 249
• Income Tax = 250
• Social Security taxes = 251
• Individual Offshore Taxation Privileges = 252
• Double Tax Treaties = 252
• Table of Treaty Rates = 253
• SELECTED BUSINESS CONTACTS = 255
• LABUAN GOVERNMENT = 256
• LIECHTENSTEIN = 256
• OFFSHORE BUSINESS CLIMATE AND ACTIVITIES = 256
• Offshore Operations = 256
• Tax Treatment of Offshore Operations = 256
• Taxation of Foreign and Non Resident Employees = 257
• Exchange Control = 257
• Offshore Activities = 257
• Employment and Residence = 258
• CORPORATE TAXES = 258
• Profits Tax = 258
• Calculation of Taxable Base = 259
• Net Worth Tax = 260
• Stamp Duty = 260
• Turnover Tax = 260
• Property Profits Tax = 261
• Value Added Tax = 261
• Withholding Tax = 261
• Filing Requirements and Payment of Tax = 261
• PERSONAL TAXES = 261
• Residence and Liability for Taxation = 262
• Income Tax = 262
• Net Worth Tax = 263
• Gift and Estate Tax = 263
• Property Profits Tax = 263
• DOUBLE TAXX TREATIES = 264
• The Austria Double Tax Treaty = 264
• International Criminal Co-operation = 264
• SELECTED BUSINESS CONTACTS = 265
• Accounting and Auditing = 265
• Banking Services and Asset Management = 265
• Offshore Company and Ship Registration = 266
• Agents and Stockbrokers = 267
• Law Firms = 267
• Trust Management = 267
• LUXEMBOURG = 269
• OFFSHORE AND BUSINESS CLIAMTE = 269
• Forms of Offshore Operation = 270
• Tax Treatment of Offshore Operations = 270
• Taxation of Foreign and Non-Resident Employees = 271
• Offshore Activities in Luxembourg = 272
• Employment and Residence = 272
• Relationship with the EU = 272
• Government = 273
• Economy and Currency = 273
• Entry and Residence = 274
• Business Environment = 274
• Foreign Investment in Luxembourg = 275
• CORPORATE TAXES = 275
• Scope of Income Tax = 275
• Income Tax Rates = 276
• Calculation of Taxable Base = 276
• Municipal Business Tax on Profits = 278
• The Fortune Tax = 278
• Taxation of Partnerships = 278
• Filing Requirements and Payment of Tax = 279
• Withholding Tax = 279
• PERSONAL TAXATION = 279
• Residence and Liability for Taxation = 279
• Income Tax = 280
• Municipal Business Tax on Profits = 280
• The Fortune Tax = 281
• DOBLE TAX TREATIES = 281
• Treaty Provisions = 281
• Table of Countries and Rates of Withholding Tax = 282
• SELECTED BUSINESS CONTACTS = 284
• MADEIRA = 287
• OFSHORE AND BUSINESS CLIMATE = 287
• Population = 287
• Relationship with the EU = 288
• Government = 288
• Economy and Currency = 289
• Entry and Residence = 289
• Business Environment = 289
• Import of Foreign Capital = 290
• Investments by Foreigners = 290
• Free Trade Zone = 290
• OFFSHORE NAD TAX REGIME = 291
• Forms of Offshore Operation = 292
• Tax Treatment of Offshore Operations = 292
• Taxation of Foreign Employees of Offshore Operations = 295
• Exchange Control = 295
• Offshore Activities = 296
• Employment and Residence = 296
• CORPORATE TAXES = 297
• Income Tax = 297
• Rates of Income Tax = 297
• Calculation of Taxable Base = 297
• Filing Requirements and Payment of Tax = 298
• Withholding Tax = 298
• PERSONAL TAXES = 298
• Residence and Liability for Taxation = 298
• Income Tax = 299
• Social Security Taxes = 300
• Stamp Duty = 300
• Value Added Tax = 300
• Municipal Property Tax = 300
• Double Tax Treaties = 300
• Table of Treaty Rates = 301
• Other International Agreements = 302
• SELECTED BUSINESS CONTACTS = 303
• GOVERNMENT AGENCIES = 303
• Accounting and Auditing = 303
• Banking Services and Asset Management = 303
• Offshore Company and Ship Registration = 304
• Law Firms = 305
• Tax Planning = 305
• Trust Management = 306
• MALTA = 307
• OFFSHORE AND BUSINESS CLIAMATE = 307
• Population Language and Culture = 307
• Government = 307
• Economy and Currency = 308
• The Malta Stock Exchange = 309
• Entry and Residence = 309
• Business Environment = 310
• Investments by Foreigners = 311
• OFFSHORE SECTOR AND BUSINESS ACTIVITIES = 311
• Tax treatment of Offshore Operations = 311
• November 2000 Budget Amendments: = 313
• Taxation of Foreign Employees of Offshore Operations = 314
• Exchange Control = 314
• Employment = 314
• CORPORATE TAXES = 315
• Income Tax = 315
• Rates of Income Tax = 315
• Branch or Subsidiary = 315
• Calculation of Taxable Base = 316
• Filing Requirements and Payment of Tax = 316
• Withholding Tax = 317
• PERSONAL TAXES = 318
• Residence and Taxation = 318
• Income Tax = 318
• Social Security Taxes = 319
• Stamp Duty = 320
• Value Added Tax = 320
• Double Tax Treaties = 320
• Table of Treaty Rates = 321
• SELECTED BUSINESS CONTACTS = 322
• Government Agencies = 322
• Accounting and Auditing = 322
• Banking Services and Asset Management = 323
• Offshore Company and Ship Registration = 323
• Law Firms = 325
• Trust Management = 326
• THE ISLE OF MAN = 327
• OFFSHORE AND BUSINESS CLIAMATE = 327
• Relationship with the EU = 328
• Government = 328
• OFSHORE AND TAXES = 328
• Forms of Offshore Operation = 329
• Tax Treatment of Offshore Operations = 330
• Taxation of Foreign Employees of Offshore Operations = 330
• Exchange Control = 331
• Offshore Activities = 331
• Employment and Residence = 331
• CORPORATE TAXES = 331
• Scope of Corporation Tax = 331
• Corporation Tax Rates = 332
• Calculation of Taxable Base = 333
• Taxation of Trusts = 333
• Filing Requirements and Payment of Tax = 333
• Withholding Tax = 334
• PERSONAL TAXES = 334
• Residence and Liability for Taxation = 334
• Income Tax = 334
• Customs Duties = 335
• Social Security = 335
• Double Tax Treaties = 335
• SELECTED BUSINESS CONTACTS = 336
• Government Agencies = 336
• Accounting and Auditing = 336
• Offshore Company & Ship Registration = 337
• SUPPLEMENTS = 341
• SELECTED SOURCES OF OFFSHORE INFORMATION = 341
• CORPORATE AND OFFSHORE GLOSSARY = 346