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There are many legitimate and highly effective ways for individuals and corporations to reduce their tax bills - and we know about most of them. If there's a legal way to reduce your tax exposure, we'll find it!

“No man in the country is under the smallest obligation, moral or other, so to arrange his legal relations to his business or property as to enable the Inland Revenue to put the largest possible shovel in his stores. The Inland Revenue is not slow to take any advantage which open to it under the Taxing Statutes for the purposes of depleting the taxpayer’s pocket. And the taxpayer is in like manner entitled to be astute to prevent, so far as he honestly can, the depletion of his means by the Inland Revenue”.

Law Lord Clyde (Ayshire Pullman Motor Services v Inland Revenue Comrs [1929] 14 Tax Cas 754, at 763,764).

Case study 1

Intermediate Group Holding Company: Telco Ltd, a company incorporated and managed in South Africa and engaged in telecommunication services, is going to invest in China.

Case study 2

Intermediate Finance Company: An Israeli investor is investing in the Czech Republic. A substantial part of the investment will be financed with debt. As the Czech withholding tax on interest paid to Israel is 10%, he wonders whether this withholding tax can be avoided by structuring the loan through a third country.

Case study 3

Licensing company: Zoomcopter holds the worldwide patents on an invention and it wonders how the exploitation of the patents can be arranged in a tax-effective manner.

Case study 4

Personal service company: Albert Smith is currently working in Luxembourg as an independent IT consultant through a Luxembourg management company. Therefore, he is currently paying Luxembourg taxes (rates up to 38%). Mr. Smith is going to conclude a new service contract to work in Italy for a US-company. The US company has a European office in the UK. It is contract work and the US company is using Albert's services by sub-contracting him out to one of its clients in Italy.

Case study 5

International trading companies: Yuri Ivanov lives in Russia. He is purchasing and selling shoes. He buys the shoes from Italy and sells them to department stores in France, Germany and Spain. Mr. Ivanov wonders whether he can structure his business in a tax-effective manner, for example by using an offshore company.

Offshore E-commerce case study 1

Electronic products business to business case study: Company A is based in the UK and has been selling computer software to businesses for a number of years using a mail-order catalogue and a small direct sales force. It has successfully set up a UK web site that allows the purchase and shipping of software to customers' homes and businesses. The web-site has started to generate significant quantities of non-UK orders from around the world.

Offshore E-commerce case study 2

Electronic products consumer case study: Company Z is a privately-owned, UK-based retailer of CDs through its network of high street shops, which have been trading for the last 25 years. It has not yet established a web site, and is keen for this to be combined with digital delivery of music to customers if this is possible. Company Z employs Netbased Ltd, a e-commerce consultancy firm, to produce a report on the introduction of a web site and the feasibility of introducing digital products.

Demand

Over the past twenty years increasing client demand for International Financial Facilities and International Tax Planning solutions. The political and economic catalysts that influence the growth of our services are:

IFSC

International Financial Service Centers: a business location possessing elements of the following four characteristics: Business is transacted mainly with non-residents. Financial regulation and corporate legislation are designed to attract international business. Confidentiality in financial affairs is paramount. Advantageous tax regimes are deliberately managed.

Switzerland types of company

Switzerland is a 'code' country, and business entities are governed by the Civil Code. As in all civil law jurisdictions, formation and administration of companies tends to be considerably more bureaucratic than in common law jurisdictions. Although the Civil Code is at Federal Level, businesses are domiciled in a particular canton.

Luxembourg types of company

In July, 2006, the European Commission ordered the government of Luxembourg to dismantle its system of tax breaks for financial holding companies, after concluding that the preferential tax regime in favour of Luxembourg’s Exempt, Milliardaire and 1929 Financial Holding companies violates EC Treaty state aid rules. (The existing regimes are described in Offshore Legal and Tax Regimes.)

Cyprus types of company

Cyprus Private Company Limited by Shares: The relevant legislation is Cyprus Companies Law, Cap. 113, which is virtually a copy of the English 1948 Companies Act. A private company is one which by its articles: Restricts the right to transfer its shares.

Belize types of company

Belize International Business Company:The following are the main characteristics of an IBC: There is no minimum paid up capital requirement, and capital may be expressed in foreign currency; An IBC may issue bearer shares and shares of no par value; but bearer shares must be held in the custody of a local registered agent

Isle of Man types of company

The UK's three IOFCs, Jersey, Guernsey and the Isle of Man have developed in different ways; the Isle of Man is not dominated by any one particularly activity, but has across-the-board strength in the financial sector, with substantial business in banking, fund management and captive insurance. The Isle of Man has also encouraged manufacturing and trading operations, which can be fiscally offshore while staying within the EU's VAT regime.

Consultation and Solutions

It is important to us to forge a good relationship with each of our clients in order to have a better understanding of their needs and objectives. One aspect of this will be the investment brief which forms the basis for the service we provide and is crucial for its success.

Case study 8

Real property companies: Ferenc Kiss, a Hungarian high net-worth individual living in Budapest, is investing substantial amounts of his wealth in real property, both in Hungary and in other Central and Eastern European countries.

Case study 9

Income arising overseas: Nancy Johnson, a Canadian individual, has acquired some luxury apartments in France along the coast of the Mediterranean. It is her intention that the apartments will be rented out to third parties. In case of sale of the apartments or when Nancy dies, capital gains taxes and inheritance taxes should be avoided or reduced as much as possible.

Case study 10

Estate Planning: Bernard Shaw, a widower of 65, is planning to remarry with a Canadian woman and emigrate to Canada. At present, Mr. Shaw is resident in the UK. He has two children; a son living in the Bahamas, and a daughter who married a German man and has been a resident of Germany for more than 10 years. His new wife also has two children from her first marriage; a son who lives in Brazil, and a daughter living in the United States.

Case study 11

Divesting of personal assets: Olga Barschefsky, an individual living in Moscow, is a chemical engineer and managing director of a Russian company engaged in the manufacturing of masks protecting against biological and chemical weapons. The Russian company has received a license for the production of these masks from Olga who holds the world-wide patents on a new revolutionary invention which is used when producing the masks.

Case study 13

Pre migration planning: Mr. Abdullah, an executive working for a big oil company in Kuwait and also resident in Kuwait (0% income tax) is sent by his employer to Germany to become the CEO European operations of his company. It is expected that he will stay in Germany for a long period of time (at least 8 - 10 years) and he takes his family with him to Germany.