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I am a UK resident and I want to setup a company that manufactures physical goods in Korea and sells/distributes them in Western and Eastern Europe and North America. The turnover would be in usd 1-2m region annually with profit at ~40%. Can this type of activity be classified as e-commerce (if we setup website)? What is the best place to setup such a company as well as offshore bank account for the partners so that the dividend is not repatriated to the UK. Kristina
REPLY:
Malta is an ideal jurisdiction to set up a company involved in international trade. Non-resident shareholders of a Maltese company will only pay 5% tax. Please contact me at pbt@maltanet.net and I will provide you with all the necessary information.
REPLY:
It is possible to put in place a structure that will allow you to split profits and retain them in a secure, confidential offshore environment by using an offshore company incorporated in Belize. Belize is considered one of the most confidential and tax efficient jurisdictions available. As you are UK resident individuals it will be necessary to also utilise a Trust for each shareholder of the company to hold your shares and also to utilise a nominee director as director of the company so as to avoid an ownership and control situation. Please contact us to discuss at enquiries@turnerlittle.com or via our web site at www.turnerlittle.com Advisor - Turner Little
REPLY:
Dear Sir,
I would suggest to you to choose Hongkong for your jurisdiction. Clean tax reputation, territorial taxation and high prestige would serve your best interests.
We are a Hungarian law office in Budapest, specialized to international tax planning. Kindly contact us for further information, our website is www.drtoth.eu.
Kind regards, Dr. Zoltan K. Toth
REPLY:
Hi Kristina Why not visit our site (www.companiesexpress.com) to see the various jurisdictions we incorporate companies in and contact us for more information. Ryan
REPLY:
Hi Kristina, we can assist you with setting up a company and bank account in a multitude of offshore jurisdictions. Please contact me and we can discuss the best option for you. natasha@palladiumtrustservices.net. Kind Regards, Natasha
REPLY:
In relation to your concerns we incorporate is aprox 95 worldwide jurisdictions, please send me a detailed email and we will advise accordingly.
Thanking you in advance for your kind attention.
info@uae-eu.com adrian
REPLY:
Dear Sirs
After reading your post on Lowtax.com please note that from our 92 Jurisdictions which we service the most appropriate in your particular case is either Gibraltar or UAE as they both address your particular concerns. Please note that the recommendation is based on the information at hand however once we further progress there is a possibility that the recommended jurisdiction may need to be changed to address your particular needs.
We are able to offer complete corporate services in all Jurisdictions directly via our own offices.
There are 27 Free zones available in UAE and within these aprox 20 different structures that may be used, therefore we have 540 options available as a starting point and then these need to be adapted to the needs of the customer in relation to their specific requirements for employees, operating areas and licences. However there is also the normal IBC structure in which we are able to deliver in aprox 3 working days.
In relation to Gibraltar there are various options which are attractive especially with the Cat 2 highly tax efficient Immigration programmes.
The two jurisdictions offer spectacular value especially when coupled to multi jurisdictional structures or trusts. Additionally we are able to structure your online multicurrency bank account without the need to visit.
Please see our website www.uae-eu.com for more information on our Company and products.
In order to download our UAE Corporate Offshore Brochure please visit http://www.uae-eu.com/pdf/rak_offshorebrochure.pdf
I look forward to hearing from you, should you wish to take the matter further please send me an email to adrian@uae-eu.com for a free no obligation initial consultancy.
REPLY:
Gibraltar is a completely inapropriate jurisdiction for your company and in all UAE and other cases proposed the ultimate issue is that your personal residential location will have an effect on your taxable income or control of an offshore company irrespective of it's location. To form a company that will work for you, you must address personal residency issues otherwise any fanciful ideas will simply not work.
REPLY:
your best solution is to set up an onshore/offshore company in malta where max taxation is 5%. as an onshore company your residency will have no relation to the corporate taxation issue and u can do what u want with the dividend. we also have trust accounts which could take care of that side of the problem too. malta has one of the best internationally recognised onshore/offshore legislation and financial services in europe which seem to meet your requirements adequately. if interested u may contact me on fcamilleri@intertecnica.com.mt or skype me on : fcamilleri Frank Camilleri
REPLY:
Hi Kristina,
Malta would indeed offer you a lot of options.
We can offer you a turn key project that includes your Maltese Trading Company and a fully fledged state of the Art E-Commerce platform including a merchant account and most importantly a Central European Drop shipping Logistic Center (at very very low cost) that actually takes care of the distribution of the goods. This is very important since shipping costs are a big costs to your business. Means, shipment from Korea goes to Central Stores any order will be dispatched from there to the customer, whilst all the money flows via Malta.
Your Maltese Company will be paying 35% Tax, but you could apply for a refund of up to 6/7, which effectively brings you back to 5% net taxation.
In Malta it is possible to hold shares by Nominee. The Nominee shareholding is strictly regulated here, therefore safe and sound. The payment of dividends can be structured in 1001 way. However, please always bear in mind that since noone in Malta will ever declare your income to anyone, you would be voluntarily obliged to declare any dividends in your home country regardless of the final destination of the money.
Recent changes in Income Tax regulation for Malta Foundations may even make it sensible to hold shares by a Malta Foundation. This would be the creme dela creme of confidentiality and asset protection. Please contact me if you like to know more about that. http://eu-hub.com/the-private-malta-foundation
info(at)eu-hub.com www.eu-hub.com Eu-Hub Malta Limited A Hilton
REPLY:
Hi Kristina, I would recommend you Hong Kong. For trading of goods outside their territories no profit tax franco
REPLY:
Hi - the main question should not be the jurisdiction for tax but the structure for effectibe transfer pricing. Assuming you will be compliant (unless the goal is to not report income, which is not a good idea under any circumstances)it is important to demonstrate WHY you book profits overseas, rather than setting up a brass plate company. I would suggest investigating this before deciding on the jurisdiction.
www.etreasurer.com etreasurer
REPLY:
Hi Kristina, your best solution is to set up an offshore company in Mauritius where taxation is 0% . If interested u may contact me on ldabcglobal@intnet.mu or visit our website www.abcmanagementservices.com.
regards Laurent Dominique Laurent Dominique
REPLY:
Hello - The individual above who focussed on your residence / domicile rather than the jurisdiction of incorporation is quite correct; all the other replies miss this crucial point. I'd be happy to talk you though the issues; my telephone number is on our website. www.middletonkatz.com Martin Katz, Chartered Secretary, Isle of Man
REPLY:
Please send me on email on nnagawa@prime-capital.mu
REPLY:
Dear Kristina,
It depends what are the countries (especially in Western Europe)where you will supply the goods, please let me know, best regards manlio
REPLY:
Being UK resident individuals, the repatriation of funds to the UK is not necessarily the problem, it is the earning of income globally by that individual or via a corporate entity in which the individual has an ownership stake or control of, which will incur you in a liability within the UK on globally earned income, except where a double taxation relationship exists and taxation has already been paid to the country holding the double taxation relationship with the UK.
On this basis, in the first instance it is vital that whatever structure you put in place, you do not have 'ownership or control' of it and this can normally be achieved by using an ownership vehicle, such as a Trust or Nominee Shareholder and by using a Nominee Director. The location of the company itself is of paramount importance also and may as well be located in a low tax confidential jurisdiction, such as Belize.
The second problem you have is that having put in place an appropriate trading structure such as that described above, you need a way of either accessing funds legally without incurring a tax liability ot a way of repatriating funds to the UK without incurring a tax liability while remaining resident in the UK.
The latter leg of the structure involves putting in place genuine loan arrangements with offshore banks to enable funds to be repatriated as loans as opposed to earned income, with loans not being taxable. The loan MUST be able to be evidenced and backed up by a genuine bank hence an appropriate relationship is required here also.
Please feel free to contact us for further information by email to enquiries@turnerlittle.com or via our web site at www.turnerlittle.com Turner Little Limited - www.turnerlittle.com
REPLY:
A GBL 2 Mauritius Company can offer you 0% corporate tax and no VAT along with a merchant account to accept card payment from a leading bank in Mauritius. Please contact me on nnagawa@prime-capital.mu so that we can send more details to you or visit www.prime-capital.mu
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