tax saving structures
Post on 14-Feb-2016
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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
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
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
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
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
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
MALTA COMPANY
No withholding tax on outbound dividends
0-5% net effective tax on trading profits
Country A High tax country
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
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%
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
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
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
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
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