Our Global Solutions
A properly configured and managed company can provide substantial tax benefits, protect assets, improve business efficiency, reduce costs and maintain confidentiality; an improperly configured offshore company is a recipe for disaster for the owner and his business. The necessity for some or all of the optional services will always depend on the actual circumstances of each individual client, and his business. These options should best be considered before placing an order for incorporation, although their integration at a later stage is also possible.
A properly structured and managed company can provide substantial tax benefits, protect assets, improve business efficiency, reduce costs and maintain confidentiality.
TBA & Associates is a UK consulting company focusing in tailor-made solutions for wealth preservation and enhancement, designing tax efficient structures to facilitate cross-border transactions.
We are regarded as one of the leading advisors in national and international company formation and management services.
We create unique structures with a strong focus on your business growth under financial efficiency.
Low Tax Offshore Companies
Tax Haven Jurisdictions
Low tax offshore companies also refer to different types of offshore companies that can be formed in an offshore centre or jurisdiction such as the British Virgin Islands, Belize, the Seychelles or RAK UAE.
Companies incorporated in jurisdictions offering both offshore and onshore companies, they may benefit from favourable tax regulation and/or special offshore company regimes.
Mauritius is an example; it has two types of companies that are used both for offshore business and international tax planning. The Mauritius GBC II Offshore Company pays zero tax and is effectively a tax haven company, similar in many respects to a BVI Company, whilst the Mauritius GBCI Company is tax resident and typically utilised for double tax treaty and international tax planning.
Hong Kong is another example; although not typically regarded as a tax haven, it has a favourable tax regime which effectively means that properly structured, managed and administered Hong Kong companies can be used to undertake offshore business and international business without paying tax in Hong Kong provided that incomes are generated overseas (outside HK). This type of tax regulation is known as “territorial taxation”.
The US LLC
Limited Liability Company
The UK LLP
Limited Liability Partnership
Fiscally Transparent Companies
The LLC or Limited Liability Company and the LLP or Limited Liability Partnership type of company, are a particular class of company used for international business and tax planning, due to their advantage of limited liability and the flow-through characteristics of a partnership for tax purposes.
This means that profits are divided amongst the members, in proportion to their respective ownerships, and are taxed in their hands; Under certain circumstances, if all the members or partners are non-tax resident in the domicile of the LLC or LLP company and no business is undertaken in that country, neither the LLC or the LLP company nor the members or partners will be subject to tax in the company’s country of establishment. Such companies are said to be “fiscally transparent” and examples include US LLCs and the UK LLP.
Companies Incorporated in
Tax Advantageous Onshore Jurisdictions
There are several countries as known as Onshore Countries, offering tax regimes that are by statute tax advantageous for specific international purposes.
Offshore business consists not only of tax havens but also of onshore high tax countries competing to attract international companies and individuals with a wide manner of tax planning regulations and opportunities. These tax advantageous regulations are used for a large variety of tax planning business, such as:
Double tax treaty planning relating to dividends, interest and royalty payment
The establishment of holding, international headquarter treasury and finance operations
Specialist business, for example, leasing
Personal and family wealth management and tax planning
In fact, almost all countries offer tax regulations of one kind or another to encourage inward investment.
International tax advisers have long been aware of the opportunities which exist for improving tax efficiency by using the special low tax regimes offered by high tax countries seeking to encourage international business.
However, successful implementation of such structures is dependent on a wide range of issues, often relating to matters such as anti-avoidance provisions, double tax avoidance, controlled foreign company and management and control tests and provisions, transfer pricing, thin capitalisation, participation exemptions, capital gains tax and a myriad of other ever-changing tax regulation.
More recently, the weapons contained in the armoury of the tax collectors have been supplemented by exchange of information treaties and provisions.
So, today the offshore world includes the expert implementation of specific tax advantageous structures domiciled in high tax onshore countries as diverse as the UK, Singapore, Belgium, Austria, Spain, Switzerland and others.