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Tax Saving Structures. No withholding tax on outbound dividends . MALTA COMPANY. Tax exemption on income. 0% withholding tax based on the PSD. EU COMPANY. - PowerPoint PPT Presentation

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Page 1: Tax Saving Structures
Page 2: Tax Saving Structures

MALTA COMPANY

EU COMPANY

No withholding tax on outbound dividends

Tax exemption on income

0% withholding tax based on the PSD

Capital gains tax protection based on several DTT’s including Denmark, Italy, Sweden, Germany, Czech Republic, Poland, Slovenia, Spain, Portugal, United Kingdom

Page 3: Tax Saving Structures

MALTA COMPANY No withholding tax on outbound

dividends Tax exemption on income

0% withholding tax based on the broad implementation of PSD

Capital gains tax protection based on DTT

LUXEMBOURG HOLDING COMPANY

Page 4: Tax Saving Structures

MALTA COMPANY

DUTCH HOLDING COMPANY

No withholding tax on outbound dividends

Tax exemption on income

0% withholding tax based on the broad implementation of PSD

Capital gains tax protection based on DTT

Page 5: Tax Saving Structures

MALTA COMPANY

GERMAN COMPANY

No withholding tax on outbound dividends

Licensing or financing activities Profits subject to 0-6.25% effective tax

0% withholding tax on interest and royalty payments based on DTT

Page 6: Tax Saving Structures

MALTA COMPANY

0-6.25% effective tax on passive interest income

No transfer pricing documentation

TREATY COUNTRY/ EU COUNTRY AFFILIATED

DEBTOR Reduction of WHT based on treaty Exemption from WHT based on EU

interest and royalty directive

Loan

InterestPayment

Page 7: Tax Saving Structures

MALTA COMPANY

0-6.25% effective tax on passive licensing income

No amortisation – IP contributed at nominal valueTREATY COUNTRY/ EU

COUNTRY AFFILIATED DEBTOR

Reduction of WHT based on treaty Exemption from WHT based on EU

interest and royalty directive

License

Royalty Payment

Page 8: Tax Saving Structures

MALTA COMPANY

No withholding tax on outbound dividends

0-5% net effective tax on trading profits

Country A High tax country

Page 9: Tax Saving Structures

MALTA COMPANY

No withholding tax on outbound dividends

Refund on dividend distribution

FOREIGN SHAREHOLDER

MALTA LICENSED GAMING COMPANY

Profits subject to net effective tax of 5% plus gaming tax based on turnover

Page 10: Tax Saving Structures

MALTA COMPANY

No withholding tax on outbound dividends

Refund on dividend distribution

SHAREHOLDER

MALTA E-COMMERCE COMPANY

Profits subject to net effective tax of 5%

Page 11: Tax Saving Structures

No withholding tax on outbound dividends

Effective management and control in Malta

Company subject to tax on income arising and on income remitted to Malta only

CYPRUS COMPANY EFFECTIVELY MANAGED

& CONTROLLED IN MALTA

Income not subject to tax in Cyprus

Page 12: Tax Saving Structures

MALTA COMPANY 0-6.25% effective tax No transfer pricing

documentation No withholding tax on interest

payments

OFFSHORE COMPANY

TREATY COUNTRY/ EU COUNTRY

AFFILIATED DEBTOR

Reduction of withholding tax based on treaty

Exemption from WHT based on EU interest and royalty directive

Loan

Loan

Interes

t Pay

ment

Interes

t Pay

ment

Page 13: Tax Saving Structures

MALTA COMPANY 0-6.25% effective tax No transfer pricing

documentation No withholding tax on royalty

payments

OFFSHORE COMPANY

TREATY COUNTRY/ EU COUNTRY

AFFILIATED DEBTOR

Reduction of withholding tax based on treaty

Exemption from WHT based on EU interest and royalty directive

Royalty

Paymen

t

Royalty

Paymen

t

Owner of IP

Sub- License

License

Page 14: Tax Saving Structures

Tax transparent Income attributable to the trust is

not subject to tax in Malta Look-through approach –

income directly received by the beneficiary

Non-residents not subject to tax other than on income arising in Malta or the transfer of immovable property in Malta

MALTA TRUST

Page 15: Tax Saving Structures