Belize: Offshore Legal and Tax Regimes
Tax Treatment of Offshore Operations
International Business Companies
Under the International Business Company Act of 1990, IBC's are exempt from most types of taxation. Exemptions include:
- all income of an IBC;
- all dividends paid by an IBC to persons resident in Belize or elsewhere;
- all interests, rent, royalties, compensations and other amounts paid by an IBC to persons who are not residents in Belize;
- capital gains realized on any shares, debt obligations or other securities of an IBC by persons who are not residents in Belize.
IBC's are exempt from the payment of stamp duty on:
- all instruments relating to transfer of any property to or by an IBC;
- all instruments relating to transactions in respect of the shares, debt obligations or other securities of an IBC;
- all instruments relating in any way to the assets or activities of an IBC.
Provided that the settlor is not resident in Belize during a tax year, that none of the beneficiaries are resident in Belize during that year, and that the trust property does not include any land situated in Belize, exemptions include:
- the income of the trust for that year from all provisions of the Income Tax Act;
- no estate, inheritance, succession or gift tax or duty is payable with respect to the trust property by reason of any death occurring during that year; and
- no stamp duty is payable on all instruments executed in that year and relating to the trust property or to transactions carried out by the trustee on behalf of the trust.
For the purposes of the Exchange Control Regulations, 1976, with regard to the trust property and to all transactions carried out by the trustee on behalf of the trust, a trustee of an exempt trust is considered non-resident.
A Belize International Bank is exempt from all forms of taxation on its profits or gains, or upon any interest or dividends earned in respect of banking business carried on from within Belize; also there is no stamp duty on Bills of Exchange or promissory notes or any other document, instrument or certificate executed by or in connection with an offshore banking business. At the time of writing:
The annual license fee for a Class A (Unrestricted) Banking License is USD20,000 for assets of up to USD30m, USD25,000 for assets between USD30m and USD100m and USD40,000 for assets above USD100m; the annual license fee for a Class B (Restricted) Banking License is USD20,000.
The annual tax is calculated at USD0.10 per net ton or fraction thereof. Most other government fees vary depending on the gross tonnage of the vessels, for example:
- Registration Fees USD300 - USD3,000
- Annual Service Tax USD300 - USD3,000
- Annual Inspection Tax USD500 - USD3,000
There are also other miscellaneous documentary fees and taxes:
- Ownership documents USD300
- Ship mortgages USD750
- Mortgage supplements, addenda or assignments USD300
- Discharge deeds USD200
According to the International Merchant Marin Registry of Belize (IMMARBE), the annual tax for a small yacht (less than 24 metres) used for non-commercial purposes is USD300. The registration fee is also USD300.
From January 1, 2013, a discount structure for new builds and large tonneage vessels was introduced. The discount is up to 50% on registration and annual fees for vessels over 25,000 gross tonnes.