International Investment in UK Real Estate
Contributed by IBSA, by Roy Saunders
30 September, 2014

Roy Saunders examines the means and methods by which international investors can invest in UK real estate.
It is common for international investors to invest in UK properties through a non-UK real estate fund. The purpose of the fund is to trade in properties or receive rental income and the fund is typically an investment company established in a tax jurisdiction with a benign tax regime. The regime should typically impose a low rate of corporation tax, exempt from tax capital gains and dividends and levy no withholding tax on distributions. The residence of the fund depends on the circumstances but usually it is either one of the EU States - Cyprus, Luxembourg, Malta, the Netherlands - or a non-EU jurisdiction - Jersey, Isle of Man, British Virgin Islands, etc.
The UK taxes property rental, property investment and property trading activities differently, as examined in their turn below.
General
Under UK law a non-resident company can be subject to corporation tax or income tax. A non- resident company is liable to corporation tax only if it carries on a trade in the UK through a permanent establishment (PE). In general, it is then chargeable on:
· trading income arising through or from the permanent establishment;
· any other income from property used or held by the permanent establishment;
· capital gains from the disposal of assets situated in the UK and used or held by the PE.
Where the non-resident company is not subject to corporation tax due to the absence of a PE or it derives income which is not connected with a PE it is liable to income tax, but only if derived from UK sources. UK source income consists of the following categories:
· trading profits from UK sources not related to a PE;
· interest income;
· rental income from immovable property situated in the UK; and
· royalty income.
With regard to capital gains, non-resident companies are only liable to corporation tax to the extent the capital gains are attributable to a PE. Additionally, it is proposed that under Finance Bill 2013 disposals by non-resident non-natural persons (essentially, companies) of UK residential real estate with the value of and exceeding £2 million will also be subject to UK tax liability.
Rental Income
UK tax charge
Non-residents who receive rental income from direct investments in UK real estate are subject to UK tax under the income tax regime. On the basis that the fund is not resident in the UK for tax purposes and provided it is not carrying on a trade in the UK through a PE (see further below), UK income tax will be due at 20% on the net income from the rental business.
The basis of assessment is the tax year that runs from 6 April of one year, to 5 April of the following year.
Most expenses incurred in the rental business, other than those of a capital nature, are deductible, provided they are incurred wholly and exclusively for the purposes of the UK rental business. These will include items such as agents fees, insurance, advertising, repair and maintenance costs.
Interest on debt is also, in principle, deductible where the interest is paid wholly and exclusively for the purposes of the UK rental business. To this end, it is common to structure internally generated finance through a separate finance company to lend to one or more offshore special purpose vehicles (SPVs) that would own the individual UK properties. This is one way to reduce the tax on the rental income. However, where the interest is paid to a connected party, the relief for interest will be limited to an amount equal to the interest that would be payable if the loan was between third parties under UKs extensive transfer pricing rules.
Withholding tax issues
Usually, where the tenant pays rent direct to a non-resident landlord, the tenant will deduct basic rate income tax at 20% from the gross rent payable, less any deductible expenses paid by the tenant. Where rental income is paid via a registered agent, the agent will similarly deduct basic rate income tax from the gross rent payable, less any deductible expenses paid by the agent.
However, a non-resident landlord can apply to HMRC to be subject to UK income tax under the self-assessment regime. Such applications are approved by HMRC on the understanding that the non-resident landlord will self-assess at the end of the year to determine whether they have any liability on the rent. If the application is approved, the non-resident landlord will be entitled to receive rental income without the deduction of UK tax.
Where rent is received after deduction of tax, the non-resident company is not obliged to file an income tax return, or notify HMRC of its investment in UK real estate. However, as stated above, the non-resident landlord can elect to file a tax return, and it will usually be to the landlord's benefit to do so in order to receive rental income gross and claim relief on all relevant expenditure.
Sale Proceeds
Investment vs. Trading
As regards the sale proceeds realised by the fund on the sale of the UK real estate, the treatment of such profit for UK tax purposes depends upon whether the fund holds the real estate as an "investment" or a "trade". If the transaction is regarded as an investment, the sale proceeds upon a disposal are considered to be capital gains and thus not taxable since a non-resident is not liable to UK capital gains tax unless it carries on a trade in the UK through a PE. However, the gains arising from the disposal of the UK real estate by the fund will be subject to UK tax as trading profits if:
· the property was sold in the course of a trade; and
· the trade was conducted in the UK.
With regard to land transactions, it should be noted that HMRC regard "trading" as a question of fact and each case is assessed separately. When deciding whether the real estate was acquired for investment or trading purposes, a number of factors are taken into account. HMRC would look at the intention at the moment the fund acquires the land. The questions that are normally asked to determine whether a trade exists include:
· What is the motive of the acquisition of the property?
If it was to generate income, the transaction is likely to be an investment; however if it is to generate a profit on sale it is likely to be dealing in UK property and thus trading.
· What is the evidence available to substantiate the claim to motive?
Do board minutes (or other documentation where the owner is not a company) exist which evidence the intentions of the directors to acquire property for investment or trading?
· What is the method of finance?
If the funds are short term in nature this is indicative of an intention to quickly dispose of the property and therefore indicative of an intention to deal/trade in UK property.
· Is the property income producing?
If a property produces no income it is difficult to show that it was bought as an investment.
· What is the period of ownership?
Property investments are normally held for a period of several years whereas a trading transaction would normally be one where the property is acquired, possibly renovated and then sold at a profit within a relatively short period of time. There is very little case law on this particular matter so to give any firm indication of what is an appropriate length of time is very difficult.
· What is the expertise of the owner?
HMRC generally contends that a property developer is more likely to acquire a property for dealing than as an investment.
Income or Corporation Tax?
The general rule is that if the profits derived by the fund represent trading income derived from a UK source, the tax liability will be income tax at the basic rate of 20%. However, if the UK activities are carried out through a PE in the UK, the profits will be subject to corporation tax at a rate of 24%.
The definition of a PE is found in the UKs double tax treaties, but this varies from treaty to treaty. Where a treaty does not apply, the UK definition is relevant.
Treaty Protection
No liability to either income or corporation tax on trading profits (or investment income) will arise if the non-resident company is resident in an appropriate double tax treaty jurisdiction, meaning that a treaty applies that, absent a permanent establishment, does not allow the UK to tax gains realised directly or indirectly on the disposal of immovable property. In such a case, the relevant double tax treaty will override the domestic definition of a PE, so as to shift the taxing rights in respect of those profits from the UK to the foreign country in question.
With respect to income or gains from real estate, double tax treaties usually contain several articles (that is, income from immovable property, business profits and capital gains) that would allow a State in which the real estate is situated to subject the income and gains to tax. Which specific article to apply depends on how the income or gain is characterised under the law of the State in which the real estate is situated.
If the profits of the proposed transaction would be considered to be trading income for UK tax purposes, gains realised on the sale of land in the case at hand would be characterised as trading income (business profits), and indeed this is the treatment which would prevent the application of section 752ff. ITA 2007 (see below). It follows that the taxation of these profits can only be allocated to the UK if all the conditions of the Business Profits article of the treaty are met; that is, if there is a PE through which the Fund is trading.
According to Article 5 of the OECD Model Tax Convention, which has been used as the basis for most of UKs double tax treaties, a PE will exist in the State (in this case the UK) if the business of the fund is carried on through a fixed place in the UK, such as an office or place of management. The mere buying and selling of land in the UK does not of itself constitute a PE under the Article 5 definition. In this regard it is important that the fund does not use a fixed place of business in the UK or has management activities carried out in the UK. Furthermore, it is important that the fund does not have a dependent agent in the UK or someone who has the authority to negotiate and conclude contracts on its behalf.
Therefore, provided the fund does not have a PE in the UK, and effective management and control is genuinely exercised at the place of its purported residence, the profits derived from a transfer of the site should not be taxable in the UK by virtue of the Business Profits Article 7(1) of the treaty, which typically states:
"The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment."
Section 752 et seq. ITA 2007: Transactions in Land
Capital gains derived by a non-resident of the UK are generally outside the scope of UK taxation. Of particular importance are the provisions of s.752 et seq. ITA 2007, which treats capital gains made from the disposal of UK land as capital profits derived from a trade (basically, "business profits"), and subjects them to an income tax charge (in the absence of a PE) at the basic rate of 20%. The main purpose is to prevent property dealing profits being disguised as tax exempt capital gains.
Section 752 can apply to any dealings with UK land which have the effect of realising a "gain of a capital nature" from a disposal of an interest in land. For s.752 to apply a "gain of a capital nature" must be realised in one of three specified circumstances. The three circumstances are as follows (s.756(3)):
· land, or property deriving its value from land (for example shares in a property owning company) is acquired with the sole or main object of realising a gain; or
· land is held as trading stock; or
· land is developed with the sole or main object of realising a gain from disposing of the land when developed.
If none of these circumstances is present s.752 cannot apply. Even if one of the above circumstances is present the section will not apply unless a gain of a capital nature is obtained from the disposal.
If the intention at the time the UK real estate is acquired is to realise a gain on disposal, it is clear that s.752 could potentially be invoked. The provisions of s.752 are, however, blunted where the company realising the gain is resident in a jurisdiction that has concluded a favourable double tax treaty with the UK, such that the taxing rights belong to the foreign jurisdiction absent a PE existing in the UK provided that such company shows the trading nature of its activities. Under s.752 the gains from the sale of land are characterised as trading income (business profits) and as a result the UK is, in principle, only allowed to tax those profits if the conditions under the Business Profits article of the relevant treaty are satisfied. As explained above, the conditions of the Business Profits article will not be met where there is no PE in the UK.
In relation to the definition of the term "gain of a capital nature", s.772(1) stipulates that: "capital in relation to a gain, means that the gain does not fall to be included in any calculation of income for purposes of the Tax Acts otherwise than as a result of Part 18 of CTA 2010 (which stipulates similar rules for the purposes of calculation of UK corporation tax)". Part 18 of the CTA 2010 contains the same reference to the relevant provisions of the ITA.
To fully understand the implications of this definition, it is necessary to determine whether the gain to be realised would be included as income for income tax purposes, and again, the question of whether the transaction can be characterised as an 'investment' or a trade' is relevant. If the transaction is considered to be an 'investment', the gain realised would not be included in the calculation of income for income tax purposes due to the fact that the proceeds from such disposal would not constitute UK source income on which non-residents would be charged to tax. However, if the transaction is regarded as a trade, the sale proceeds upon a disposal are considered to be trading income which would be included as income for income tax purposes.
Although in the absence of the UK PE under the applicable treaty no tax would actually be levied on the fund, because it may in principle be subject to UK income tax (and therefore have these profits included in an income tax computation), the profits are not within the definition of a gain as stated in s.772(1). Thus, since the conditions of s.756(3) are not met, the charge can not apply to the fund.
If treaty relief is claimed so that the trading profit is not taxed in the UK but in the treaty Contracting State, a question arises as to whether there is in fact a computation of income for UK tax purposes. However, because s.772(1) relies to such an extent on there being a "gain of a capital nature", it is recommended that the fund files a UK self-assessment tax return with a computation of income for the purposes of income tax. At the same time, treaty relief should be claimed so that the computed income is not actually taxed in the UK but in the treaty Contracting State. In practice HMRC have indicated that they do not require a treaty claim to be made if the taxpayer feels the profit is indeed treaty protected. However, because of the potential exposure to s.772 for the fund, a computation of income should be included on the self-assessment return and an appropriate claim for relief made.
Roy Saunders
Roy Saunders is the founder and Chairman of The International Business Structuring Association (IBSA). He qualified as a chartered accountant in 1967 and created his own niche international tax practice, International Fiscal Services (IFS), in 1971. Roy has a wealth of experience in international tax matters having authored the book International Tax Systems and Planning Techniques (Sweet & Maxwell) and teaching on the MA Course on International Taxation at the Institute of Advanced Legal Studies at the University of London.
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- » Malta introduces new guidelines for long term leasing, reducing the vat liability of pleasure yachts
- » EU VAT Number
- » Business Closure Procedure to Avoid Future Taxes
- » Interview with Emily A. Georgiades on Financial Crime by Gold Magazine
- » Increased Interest by High Net Worth Individuals of South Africa for the Cypriot Citizenship by Investment Program
- » A Few Tips for Automatic Exchange of Information Reporting
- » Estate and gift taxes in Cyprus - planning is needed
- » International Tax Landscape shake-up for Multinational Businesses
- » Massive legislation changes affecting Offshore Tax Regimes and Economic Substance Requirements
- » More Corporate and Tax Legislation Changes of Offshore Companies
- » Substance and De-offshorization
- February (8)
- » Setting up and running a business in Cyprus
- » Cyprus introduces stricter rules for citizenship by investment program
- » Cyprus Intellectual Property
- » Andorra for High Net Worth Individuals
- » How to Save Money When Starting a Business
- » BVI Companies make a move towards Tax Transparency
- » Knowing your rights as a victim of financial crime
- » Benefits of Starting a Business in Malaysia
- January (5)
- » Observations of the AGM of Association of Cyprus International Investment Firms
- » Cyprus IBC Capital
- » Three Key Considerations in Establishing your Virtual Currency Investment Fund
- » Lebanon: A Case Study on Efficient Inbound Investment - Tax Structures for Cross-Border Acquisitions
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- December (10)
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- » Financial Advisor Hiring 101: What to Ask When Hiring For Your Business
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- » New rules for property tax and tax homesteads
- » Gibraltar publishes rules implementing EU rules against Tax Avoidance Practices
- » Notaries in Estonia will be empowered to certify documents via video link
- » The Cyprus Tax System Explained in a Simple Way
- » The Power of Sailing BVI Yacht Registration
- » The Intra-Corporate Transfer Regulations
- » 'The UK can unilaterally decide to Remain in the EU' - Advocate General, Court of Justice of the European Union
- » The Accounting Conundrum Solved - Accounting in the UAE Made Simple
- November (9)
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- » Investors: Applying For A Cypriot Passport? Read Our Guide
- » The Draft Withdrawal Agreement and Protocol on Gibraltar
- » Your Essential Guide to Offshore Companies in Dubai
- » Three Best Offshore Asset Structures in Belize
- » What You Need To Know About Standard Banking And Electronic Wallets
- » The Key to a Successful and Family-Friendly Career
- » European Commission proposes new Anti-Money Laundering Directive: 6AMLD
- » Gibraltar Association for New Technologies GANT
- October (9)
- » Financial Substance in Andorra - Part 1 of 2 - How And Why Did It Come About?
- » Financial Substance in Andorra - Part 2 of 2 - How To Comply With Substance In Andorra
- » CySEC: An Overview of the Cyprus Securities and Exchange Commission
- » Non-Residential Tax Returns in the UK
- » Time Is Running Out For Expats Behind on Taxes
- » GDPR WARNING: Why Not Shredding Your Data Could Cost Your Company Millions
- » Trust and Corporate Services Provider (TCSP) Licensing in Hong Kong
- » Cyprus: The Blockchain-friendly Island
- » Securing Your Children's Future with a Cyprus International Trust
- September (18)
- » 10 Most Common Tax Return Mistakes To Avoid
- » Cryptocurrency and Taxes - What You Need to Know
- » Why Getting HK Tax Residency Certificate & How to Benefit?
- » Investment Funds in Cyprus - A Guide for Global Investors
- » Why Should I Care About The FTSE 100?
- » Asset Protection: Your Personal Insurance
- » Why Switzerland Is The Best Place To Establish A Business
- » New type of funds (Cyprus): The Registered AIF (RAIF)
- » Understanding New York Real Estate Taxes
- » What are Fixed Indexed Annuities?
- » Cyprus Citizenship by Investment
- » Forming and Operating a Fund in Cyprus: A Guide for Emerging Cyprus Fund Managers and Investors
- » Cryptocurrency - a wallet or exchange?
- » Start-Up Dilemma: Things to Consider When Looking for the Perfect Office Space for Your Business to Grow
- » Investing in Self-Storage Real Estate
- » Estonia: Register of Beneficiaries in Force
- » Secure Crypto Currency to Physical Gold OTC Exchanges
- » Wolters Kluwer Tax Expert To Speak At Tax Reform Conference
- August (17)
- » Euro Exim Bank's Involvement with Blockchain Technology
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- » Iceland - Under The Radar Program
- » Launching an ICO through Cyprus
- » Is Your Significant Controllers Register (SCR) Ready?
- » 3 Simple Techniques For Contractors
- » Did you know that a $10K investment can get you a tax-free company and residency in Dubai ?
- » A Holistic Approach To Regulating Cryptocurrencies And Virtual Financial Assets In Malta
- » Quick overview of Seychelles Legal System
- » Seychelles Updates
- » Notional Interest Deduction (NID) Rules
- » Deduction For Transportation Cost Of Employees Rules
- » VAT Grouping Regulations
- » Malta Ahead Of The Game
- » Seychelles Tax treaties
- » Quick overview of Seychelles business tax
- » Gibraltar Budget 2018
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- » Just Announced: 100% Ownership for Dubai Entrepreneurs
- » Why Hong Kong is Your Essential Business Hub
- » Lasting Powers of Attorney in Gibraltar - the Act comes into force
- » The How and Why: Redomiciling your Business in Singapore
- » GDPR - Key Aspects of the General Data Protection Regulation
- » Trademarks: What is the opposition process?
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- » Financial Advising: Accounting's New Look
- » Why register a trust in Cyprus?
- » How double taxation treaties work
- March (4)
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- » Pension for Life: An Achievable Dream
- » Partnerships in Canada: tax haven or undesirable misfortune?
- » Benefits of Setting Up a Shams Free Zone Company In the United Arab Emirates
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- » The Future of Global Taxation
- » Common Standard Of Automatic Exchange Of Information On Tax Matters
- December (13)
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- » Cryptocurrencies and the mainstream - bridging the gap to mass market adoption
- » Gibraltar - DLT Guidance Notes Published
- » The High Net Worth Individual Scheme
- » Middle East Faces Significant Challenges To International Business, Survey Finds
- » What impact will Brexit have on Gibraltar Cross-Border Mergers?
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- November (4)
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- » What you "token" about?
- » Legal "non-disclosure" overseas retirement planning
- » Why is it that more businesses blame poor results on currency movements?
- » Bitcoin Tax Strategies & Corporate Structures: Why Governments Worldwide are Scared of Bitcoin's Incredible Potential
- » Build an Offshore company in Hong Kong
- » Film Production Scheme to be introduced in Cyprus
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- September (3)
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- June (8)
- » Fear Fintech? Embrace Fintech
- » Publication of Guidance Notes related to Automatic Exchange of Financial Account Information by Cyprus Tax Department
- » Law Firms and Marketing Strategy
- » Why will accountants, financial advisers and registrars lose their jobs in coming years?
- » Register of Beneficiaries in Estonia
- » Bitcoin, ethereum, crypto currency and block chain - the next industrial revolution - the new gold - from barter to bitcoin
- » Why partnering with a currency broker is a win for you and your clients
- » BEPS - What is it? & What is the cost on Africa?
- May (6)
- » Caribbean Flourishing Due to Citizenship by Investment
- » The New Zealand "Foreign Trust" regime vs the USA "Foreign Trust" Regime
- » How does one legally avoid paying more than 5% in taxes? Move your business to Malta!
- » Guide to the benefits of owning company shares through a discretionary trust
- » Four jurisdictions to start a company in
- » Global Tax Trends And Impact On Offshore Jurisdictions
- April (3)
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- February (18)
- » Exactly which US expats have to file an IRS tax return?
- » The best citizenship by investment programs for 2017
- » Don't make these tax mistakes when you retire
- » How to get a Second Passport and Second Citizenship
- » Still the easiest place in the world to open an offshore bank account
- » Get second residency and pay no tax in these 19 tax-free countries
- » The fastest countries in the world to become a citizen
- » Cyprus introduces rules to implement Country by Country reporting requirements
- » Revised criteria for granting the Cypriot citizenship by investment
- » Potential Non-Dom Solutions: QNUPS
- » Tax Calendar 2017
- » Cyprus Investment Immigration Programmes
- » Reforms to the Taxation of UK Non-Domiciles
- » Potential Non-Dom Solutions: Trusts
- » Restarting the Clock: Residency Solutions for Non-Doms
- » Tax payers given rights to claim deemed deductions on Article 33
- » Declaration of an individual as a non-dom
- » Cyprus Tax Facts 2017
- January (4)
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- 2016
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- June (8)
- » The Corporate Governance Review - Cyprus 2016
- » Double Tax Treaty between Cyprus and Latvia signed
- » How Canada Taxes Real Estate Gains Of Non-Residents
- » Cyprus - Seychelles collaboration through the double taxation treaty
- » Eight Myths Regarding Being Non-Resident For Canadian Tax Purposes
- » Tax Issues for Non-Resident Actors & Entertainers in Canada
- » The Tax-Efficient Way For Foreign Corporations To Acquire Canadian Corporations
- » Why do online entrepreneurs need to structure their companies carefully?
- May (2)
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- 2015
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- 2014
- December (2)
- November (6)
- » NEWSLETTER: THE NEW PENSION FLEXIBILITY FROM APRIL 2015: THE DETAIL EXPLAINED
- » NEWSLETTER: THE NEW PENSION DEATH TAXES FROM 6.4.15 EXPLAINED
- » NEWSLETTER: NEW CAPITAL ADEQUACY REQUIREMENTS FOR SIPP PROVIDERS AND UNREGULATED INVESTMENTS WITHIN SIPPS
- » QROPS BULLETIN - NOVEMBER 2014
- » Controlled Foreign Companies (CFC) legislation voted by the State Duma
- » Migrating the residence of the target company from Costa Rican jurisdiction raises tax consequences
- October (2)
- September (5)
- August (5)
- July (1)
- June (9)
- » Banking in a Tax Haven isn't what it used to be!
- » Italian Tax Cuts
- » Part-Time Self-Employed Tax Submission
- » Life in the Sun: The Ease of Benefitting from Tax Residence in Malta
- » Cyprus Corporate Governance 2014
- » NEWSLETTER: HMRC tightening up on SSASs, unregulated product providers targeting PSLS, recycling issues, and an international pension conference
- » The Liability of Shareholders for the Tax Debts of a Company
- » Relief from Transfer Pricing for Controlled Foreign Companies
- » DFM Platform SIPP
- May (4)
- » The Dispute Resolution Review [Cyprus], Sixth Edition, Editor Jonathan Cotton
- » QROPS BULLETIN - MAY 2014
- » Malta Individual Investor Program - Facilitating Citizenship Through Investment in the Republic of Malta
- » NEWSLETTER: SIPP opportunities, new investment challenges for IFAs and delays in SSAS registration
- April (3)
- March (6)
- » Thin Capitalization in India
- » NEWSLETTER: Budget 2014: Important changes to pensions
- » QROPS BULLETIN - MARCH 2014
- » NEWSLETTER: Reallocation of assets/Beware if setting up a new scheme to beat the end of the tax year/UK pensions for non-UK residents
- » INSIGHT SIPP
- » Important Things about Home Insurance it is Imperative You Know
- February (8)
- » Murdoch and News Corp Receive $882m Australian Tax Rebate
- » Tom Perkins Believes that Taxes will lead to 'Economic Extinction' of the 1%
- » Weariness of Refund Fraud Heightens as Tax Season Returns
- » QROPS BULLETIN - FEBRUARY 2014
- » NEWSLETTER: CHANGES COMING INTO FORCE ON 6TH APRIL 2014
- » International Civil Fraud - Cyprus
- » New Online Pension Products And Services For Advisers
- » DFM Platform SIPP
- January (3)
- 2013
- December (1)
- November (6)
- October (6)
- » Seminar Invitation: QROPS/QNUPS/IHT Implications/New Platform/Fund Management and Online SIPP
- » Cyprus: Does the Boomerang Really Come Back Sometimes?
- » QROPS BULLETIN: OCTOBER 2013
- » The Importance of Planning
- » Why Malta?
- » NEWSLETTER: Protection update and more reasons why everyone needs to save more
- September (1)
- August (4)
- July (7)
- June (6)
- » Incentives for Third Country Nationals to Invest in Cyprus - Significant Improvements
- » QROPS BULLETIN: JUNE 2013
- » Introducing the ACORN LITE SIPP for Regulated Investments & Bank Accounts
- » Inheritance Tax U-Turn: Expats Must Plan Ahead
- » Landmark Supreme Court Judgment on the Rights of Depositors
- » Newsletter - June 2013
- May (7)
- April (3)
- March (7)
- » Return to 120% of GAD and ensuring SSASs are properly run
- » QROPS for Financial Advisers QROPS Choice
- » Forming a company in Monaco
- » Increase in Minimum Annual Tax Burden in Luxembourg and Restructuring Solution
- » Announcing the Launch of an Isle of Man QNUPS
- » Monaco Residency - easy process?
- » Why consider Monaco?
- February (11)
- » UK Publishes Draft Legislation on Offshore Companies Which Own UK Property
- » New 'Approved Manager' Regulations for Hedge Funds
- » Announcing the Launch of a Guernsey QNUPS
- » Changing Gears - Investment Funds in the British Virgin Islands are Moving from Strength to Strength
- » Asset Tracing Recovery Tools in the BVI
- » Depardieu, taxes and untrodden paths
- » Why you Should Choose the BVI for your Fund
- » Fast and Simple in BVI
- » Guide to Incorporating Companies in the BVI
- » QROPS: An Overview of Jurisdictional Differences
- » QNUPS: An Overview of Jurisdictional Differences
- January (7)
- » New Modifications to the Commercial Code
- » QROPS BULLETIN: JANUARY
- » Why isn't offshore dying?
- » Laws part of the Memorandum agreed for financial assistance to be provided by the Troika voted by Cyprus Parliament
- » The Autumn Statement 2012
- » Dubai - Property ownership through company structures
- » Money Laundering
- 2012
- December (2)
- November (7)
- » The Cyprus International Trusts
- » Increase in minimum annual tax burden in Luxembourg
- » Panama's Banking Center Reports Almost 12% Growth in Assets
- » Why do business in Bulgaria?
- » Setting up an LLC in Dubai
- » BVI Law Holds Even Keel Between Rights of Investors and Rights of Mutual Funds
- » A CHOICE OF NEW SIPPS
- October (8)
- » Offshore Companies Owning UK Residential Property Need To Take Urgent Action
- » QROPS BULLETIN OCTOBER
- » Announcing the Launch of the QROPS TRANSIT SIPP
- » Unisex GAD rates and a new service for defined benefit schemes
- » Will Cyprus collapse?
- » ARBITRATION AS EXPEDITED OPTION FOR CONFLICT RESOLUTION
- » Incentives for third country nationals to invest in Cyprus
- » Insight SIPP For Sophisticated Investors
- September (6)
- » Property in SIPP/SSAS and Death Benefit Trap
- » QROPS Bulletin September
- » Panama - Training, Tax Deductible
- » NEWSLETTER: SIPP cash rates, Unisex GAD rates, annuity rates worsen even more - and opportunities for IFAs!
- » SIPP / SSAS: COMMERCIAL PROPERTY MATTERS
- » SIPP / SSAS: COMMERCIAL PROPERTY MATTERS
- August (12)
- » QROPS BULLETIN
- » NEWSLETTER: Warnings for SSASs and those with Enhanced/Fixed Protection, property and illiquidity issues and the true costs of pensions
- » Form a Singapore Company
- » Offshore Companies Owning Uk Residential Property Need To Take Urgent Action
- » U.S. Law Jeopardizes the Panamanian Banking Secrecy
- » The Professional's Toolkit Shelf Companies
- » Weathering the storm
- » Funds article for New Europe
- » Bearer shares: are their days numbered?
- » QROPS BULLETIN August
- » Incorporation In Hong Kong
- » A gateway to the booming Asian market
- July (3)
- June (5)
- May (6)
- » Trusts & Foundations - The Best Tools for Giving...
- » NEWSLETTER: Pensions post 6.4.12 – the new Rules explained
- » Why you should consider Switzerland as part of your international tax planning arrangements?
- » A Different Style : VISTA Trusts 8 years later
- » Securities and investment business regulations in the British Virgin Islands
- » VAT Yacht Leasing Scheme
- March (4)
- February (1)
- January (7)
- » Cyprus Hydrocarbons Exploration and Exploitation: the Legal Framework and Licensing for hydrocarbon reserves in Cyprus' Exclusive Economic Zone
- » Cyprus Investment Firms
- » Outward Investment from Canada - The Offshore Perspective
- » Trade Marks in Cyprus: Registration, Protection and Infringement of Trade Marks and Community Trade Marks in Cyprus
- » The Document Keeping Requirement
- » The Professional's Toolkit - Shelf Companies
- » International Financial Centre Profile
- 2011
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- » QROPS / QNUPS: Jurisdictional differences matter to Clients
- » Panama Pacifico: Gateway to the Americas
- » Income Tax Implications for Non-Residents Investing in Canadian Real Estate
- » QROPS Bulletin May 2011
- » QROPS Proposition: SIPP Specialists Hold a Unique Market Position
- » QROPS: Choice of Jurisdictions on Isle of Man
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