A high proportion
of companies engage in 'trade', that
is the process of making or procuring goods
or services and selling them on to business
or individual customers. If this process
takes place internationally, then it is
often possible to interpose an offshore
company in which part of the profits of
the operation can be realized in a low-tax
jurisdiction. Even if the process takes
place wholly in one high-tax jurisdiction,
it may be possible to separate the 'selling
on' part of the process from the 'making
and procuring' part, and send it offshore,
particularly now that e-commerce infrastructure
is available in many IOFCs.
The eventual
value of having an offshore trading company
will depend on the overall corporate structure,
and on the particular country or countries
in which the owner resides. To get the
best result, it will normally be good
for the offshore company not to be a controlled
subsidiary of the main company; and it
will normally be even better if the main
shareholders are not resident in the same
country as the main company; but even
if these conditions are not fulfilled,
there is much that can be achieved.
Here are
some examples of business situations
in which an offshore trading company can
help to reduce or avoid tax:
An EU automotive
component company sets up an independent
offshore company to purchase cheap Chinese
parts and sell them on at a profit to
the EU company, which builds them into
assemblies, adding further value (which
will be taxed in the EU).
A newsletter
and magazine publisher in the UK retains
his editorial staff there, but sets up
a separate offshore sales and distribution
company to handle the rest of the process,
and make most of the profit offshore.
An international
engineering personnel agency gives
up its Paris office and moves completely
to an offshore jurisdiction which is only
slightly less convenient for interviewing
people. Its own profits and those of its
free-lance staff become untaxed (staff
may choose to remain in a high-tax area,
but at least now they have a choice!).
Note that
the tax saved in most such cases is
income (corporation) tax; but in the case
of products or services which can be delivered
over the Internet, the possibility of
avoiding VAT also opens up. See Offshore-E-Com.com
for a fuller description of how this can
work.
It is worth
noting that some IOFCs actively encourage
trading operations by offering duty-free
zones, or warehousing facilities. This
can be particularly important when attempting
to avoid the creation of a 'permanent
establishment' in the destination country
(eg for the storage of goods before delivery)
which could compromise a company's offshore
status.
Apart from
ensuring fiscal suitability and confidentiality,
the choice of an offshore jurisdiction
for trading purposes will depend on a
variety of factors, of which some particularly
important ones may be:
good
transport links
availability
of skilled local labour
ease
of obtaining entry and work permits
proximity
to markets
local
cost levels
effectiveness
of local banking and commercial services
modern
telecommunications and e-commerce infrastructure
availability
of duty-free zones
ease
of establishment of offshore entities
Due to
the variety of possible trading purposes,
it is difficult to recommend suitable
IOFCs, but here is a list of some IOFCs
with good, broad infrastructure and which
meet many of the criteria above:
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