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Financial Holding and Investment Activities

Broadly speaking, it is larger companies, especially multinationals, that use IOFCs (International Offshore Financial Centres) for holding and investment. At one time, the tax advantages that could be got from routing investment or ownership through an IOFC had got to be balanced against the extra cost, difficulty and risk of using a possibly somewhat backward offshore island without sophisticated business infrastructure or switched-on professionals.

No longer. Some of the International Offshore Financial Centres are difficult to distinguish from centres in high-tax countries in Europe or North America in terms of financial infrastructure, while the spread of modern telecommunications, computer technology and now the Internet has pretty well done away with the difficulties of working with offshore.

Still, it is the tax advantages that drive offshore, as always, and the 500 banks in the Cayman Islands are there to reduce their own tax bills and to service the needs of corporations that want to lower their tax burdens, not because of the climate. There is a very wide variety of corporate financing and investment purposes offshore, some of which are indicated in the following list:

  • to hold foreign subsidiaries and receive dividends or interest on loans from them in a tax-efficient manner; either because there is a good tax treaty between the IOFC and the foreign country concerned; or because the IOFC itself has low taxes; or a combination of the two.
  • to concentrate the profits and losses from subsidiaries in one low-tax area, which may be more tax-efficient than remitting them to the high-tax base country separately.
  • to obtain financing from institutions that are themselves free of high taxation (especially withholding tax) and can therefore provide it more cheaply than they can from high-tax centres. Especially project finance is often assembled offshore, where the burden of regulation is lighter, alongside the tax advantages.
  • to base in-house treasury and finance departments in a flexible, low-tax environment from which they can provide the best and cheapest service to group companies wherever they may be.

Double Tax Treaties and Transfer Pricing. It may often be the case that a corporation resident in a particular high-tax country will choose a specific IOFC because of the tax situation between them. Although traditionally not many low-tax jurisdictions have had Double Tax Treaties with high-tax countries, this situation is gradually changing. One major consideration is of course transfer pricing and thin capitalization rules: whereas ten or twenty years ago corporations were comparatively free to make profits where they chose to place them, high-tax countries have now woken up to the loss of tax revenue that can occur when a multinational corporation optimizes its tax structure, and most of them have transfer pricing rules that are more onerous by the day. The use of a low-tax jurisdiction may even be a disadvantage in some cases, where for instance a high-tax country has a black-list or grey-list of countries with 'preferential' regimes, and may apply punitive rates of withholding tax.

In choosing an IOFC for financial purposes, it is the finance sector infrastructure that is most important, and here is a list of IOFCs that qualify in a general way – all of them are covered in our Jurisdictions section:

British Virgin Islands 
Cayman Islands 
Hong Kong
Isle of Man

In the Lowtax.net jurisdictions section, information is given about the financial sector for each of the following jurisdictions:

AndorraAnguillaArubaBahamasBarbadosBelizeBermudaBritish Virgin Islands,Cayman IslandsCook IslandsCosta RicaCyprusDubaiGibraltarGrenada,GuernseyHong KongIrelandIsle of ManJerseyLabuanLiechtensteinLuxembourg,MadeiraMaltaMauritiusMonacoThe Netherlands AntillesPanamaSeychelles,SwitzerlandTurks & Caicos Islands and Vanuatu.