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Belize: Offshore Legal and Tax Regimes

Tax Treatment of Offshore Operations

International Business Companies

Under the International Business Company Act of 1990, IBCs 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, compensation and other such monies 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.

IBCs are exempt from the payment of stamp duty on all instruments relatying to:

  • transfer of any property to or by an IBC
  • transactions in respect of the shares, debt obligations or other securities of an IBC
  • the assets or activities of an IBC.

Trusts

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 reference to the trust property and all transactions carried out by the trustee on behalf of the trust, a trustee of an exempt trust is considered non-resident.

International Banks

A Belizean international bank is exempt from all forms of taxation on its profits or gains, or on any interest or dividends earned in respect of banking business carried out from within Belize. In addition, 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 licence fee for a Class A (Unrestricted) Banking Licence is US$20,000 for assets of up to US$30m, US$25,000 for assets between US$30m and US$100m and US$40,000 for assets above US$100m; the annual license fee for a class B (restricted) banking licence is US$20,000.

Shipping Registration

The annual tax for shipping is calculated at US$0.10 per net ton or fraction thereof. Most other government fees vary depending on the gross tonnage of the vessels, for example:

  • Registration Fees US$300 - US$3,000 
  • Annual Service Tax US$300 - US$3,000 
  • Annual Inspection Tax US$500 - US$3,000

There are also other miscellaneous documentary fees and taxes:

  • Ownership documents US$300
  • Ship mortgages US$750
  • Mortgage supplements, addenda or assignments US$300
  • Discharge deeds US$200

According to the International Merchant Marine Registry of Belize (IMMARBE), the annual tax for a small yacht (less than 24 metres) used for non-commercial purposes is US$300. The registration fee is also US$300.

From 1 January 2013, a discount structure for new builds and large tonnage vessels was introduced. The discount is up to 50% on registration and annual fees for vessels over 25,000 gross tonnes.

 

 

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