22.32 LIECHTENSTEIN

Tucked away neatly in the mountain valley between the Swiss canton of St. Gaul on the south and west and Austria on the east and north is tiny Liechtenstein, one of the smallest countries in the world. While small in size (just 65 square miles), Liechtenstein is a giant as far as offshore financial centers and tax havens are concerned, and is reputed to be the third richest country in the world. Liechtenstein's fame doesn't stem from the mere selling of postage stamps, although a sheet of pre-war agricultural designed stamps with a face value of SFr 5 is now worth some SFr 3,000. It's Liechtenstein's celebrated tax and political systems, celebrated for its minimal taxation of foreigners, its strict bank secrecy (more impregnable than Switzerland's), and its long history of political stability that make her a powerhouse among the financial centers.

Historically the Principality of Liechtenstein comprises the former territories of the County of Vaduz and the Lordship of Schellenberg. These were first united by inheritance in 1434 with the status of fiefs of the Holy Roman Empire. As you would expect, Liechtenstein today is predominantly Roman Catholic. At the beginning of the eighteenth century the two territories were purchased separately by Prince John Adam Andrew of Liechtenstein, whose name was taken from Liechtenstein's Castle, a former family possession south of Vienna. In 1719, the two territories were formerly reunited as the "Principality of Liechtenstein".

The head of state today is Prince Franz Joseph II whose Gutenberg castle overlooks the capital of Vaduz. Inside Prince Franz' castle is a vast fortune in paintings, sculptures and tapestries, many bought directly from the great masters themselves. The royal family is also the principal owner of one of only three banks doing business in Liechtenstein, i.e., the Bank In Liechtenstein , or BIL.

As a sovereign state since 1806, Liechtenstein has developed strong ties with both Austria and Switzerland. The official currency is the Swiss Franc, which is freely convertible into any other currency at prevailing market rates. Because Liechtenstein maintains no standing army (the frontier defense is furnished by the Swiss), there is no military budget to appropriate. This little haven boasts inflation of only 1.4%, a budget surplus, and no national debt. As if all this wasn't enough to be proud about, Liechtenstein levies no income taxes against any company that is domiciled there, provided the company does not receive Liechtenstein source income.

Anstalts, Stiftungs, Holding and Domiciliary Companies

For a country of just 28,000 people, pint sized Liechtenstein boasts more nonresident business entities than population. It is said there are between 30,000 and 60,000 trusts (called Anstalts ), although the exact number appears to be a well-kept state secret. In Vaduz the lawyers outnumber the bankers. Moreover, with some 330 firms specializing in consulting, management and insurance, employing over 1,600 people, you don't have to look long for advice. A nonresident can form an anstalt (English translation is establishment ), which must have a minimum paid-in capital of SFr 30,000 (about US$18,000), or a joint stock company (or AG ) with a minimum capital of SFr 50,000 divided into either registered or bearer shares. There are two types of joint stock companies permitted, i.e., holding and domiciliary . Another unique entity called a Stiftung ( foundation ) is also popular in Liechtenstein.

An anstalt is a separate entity much like a corporation. Like a corporation, it can have a business purpose. The original founder of an anstalt is generally a Liechtenstein lawyer of trust company, but he commonly resigns after the registration and transfers all rights on a " declaration of cession " to an unnamed successor (the real investor). This document is often held in a Swiss or Austrian bank vault, keeping the identity of the client doubly obscured. An anstalt may elect to divide its capital into shares like a holding company, but if it so elects it will be subject to Liechtenstein's 4% coupon tax (a type of dividend withholding tax), as are all holding and domiciliary companies. Other than this coupon tax , an anstalt would not be subject to any income taxes in Liechtenstein. Its tax liability would be limited to Liechtenstein's annual capital tax , calculated as 0.1% of all capital and reserves.

Aristotle Onassis is said to have kept over half his wealth in a Liechtenstein "public wealth foundation", the purpose and activity of which was, and still is, a well-kept secret.

There is some doubt among professionals whether the IRS will recognize an anstalt as a legal entity, and some European courts (namely the Belgium and Italian) have held that they are not. U.S. Professor Marshall J. Langer believes the IRS might categorize an anstalt as either a trust or an alter ego of the current holder of the founder's rights. Revenue Ruling 77-214 and several letter rulings published in 1977 (and later revoked) requires every company to have associates if it is to be classed as a company for tax purposes. Since an anstalt has no associates, Langer believes Americans and other nonresidents might do best to steer clear of exploiting the anstalt, and opt instead for a domiciliary or holding company . According to Professor Langer…
" A nonresident alien should avoid using an anstalt to invest in U.S. property or securities, otherwise he runs the risk that he will be taxed personally on its income and, even worse that the Anstalt's U.S. stock and real estate will be taxable U.S. property for estate tax purposes upon his death ."

Holding and Domiciliary Companies

A holding company is a corporate body having its registered seat in Liechtenstein with a purpose of entirely or mainly administering or managing assets and investments. The domiciliary company is a legal entity incorporated in any of the forms governed by the Persons and Companies Code that has its registered seat in Liechtenstein, but carries out no commercial activities within the country. The status for the qualification as domiciliary or holding company is therefore merely a question of the company's purpose. Business entities having the status of domiciliary or holding companies are:

1. Exempt from any income tax, property tax (with exception for real estate in Liechtenstein) and capital gains tax
2. Not required to file a tax return, but merely furnish audited financial statements to the tax authorities
3. Must maintain an office in Liechtenstein, but the registered seat need be nothing more than a mailing address
4. Afforded absolute secrecy regarding tax matters.

A holding company is an AG that primarily holds shares in other companies. A domiciliary company is an AG that has its corporate seat or domicile in Liechtenstein but carries on its commercial activities outside the country. Neither pays any income tax, but instead pay an annual capital tax of 1/10th of 1% on their capital and reserves , with a minimum tax of SFr 1,000 (about US$620) payable annually.

Stamp taxes & 4% Coupon tax

Liechtenstein has a thriving industrial base in addition to its tax haven styled economy. Normal tax rates range from 7.5% to 15% for companies manufacturing within the country, with an innocuous 4% coupon tax (another name for dividend withholding tax) on cash (or in kind) distributions to shareholders. The withholding tax applies to holding and domiciliary companies and anstalts limited by shares. It is also applicable to certain loans with durations over two years.

Other hidden Liechtenstein taxes to consider are a stamp duty due on the transfer of shares or bonds in foreign (0.3%) or domestic issuers (0.15%), and a 3% formation stamp tax due on the creation of shares or participation rights in a company. To understand better how a typical anstalt domiciliary or holding company might be started-up and taxed under the Liechtenstein tax system, let's look at an unpretentious example.

Example # 1:
Nonresident international businessman X claims Campione in the nearby Swiss Alps his tax home. X invests $50,000 as paid-in capital in his Liechtenstein holding company Y , and lends an additional $950,000 short-term for two years to company Y . In 1989, holding company Y re-invests the entire proceeds in U.S. Treasury bonds issued after July 18, 1984 paying 10% interest pa.

The annual interest earned on the T. bonds would amount to $100,000 pa. No U.S. withholding tax will be withheld by the U.S. Treasury on payments of interest to Y, because the Tax Reform Act of 1984 repeals all interest withholding taxes on "portfolio" type bond interest. Since company Y does not carry-on any business within Liechtenstein, no income taxes will be levied on Y . However, a capital tax equal to 1/10th of 1% of the paid-up capital and reserves of Y (but excluding the 1st year profits of Y) will be payable annually to the Liechtenstein tax administration. This computes to a capital tax of $50. However, a minimum capital tax of SFr 1,000 (about US$620) is payable by every company, so the actual first year capital tax paid will equal $620. This equates into a 0.62% profits tax rate, so far.

Assuming no dividends are paid to non-resident shareholder X, the 4% coupon tax could be avoided, leaving no further taxes to be levied against company Y. To secure a tax free capital gain, X might sell the shares in Liechtenstein holding company Y to a friend in Campione. It should be pointed-out that when holding company Y purchases or sells the $1,000,000 in U.S. treasury bonds a stamp transfer tax equal to 0.3% (or $3,000) will be payable to the tax administration. In addition, a0.15% stamp tax on the face value of the $950,000 Liechtenstein corporate loan (or $1,425) will be payable upon its culmination with X. A one time formation stamp tax of 3% (or $1,500) of the $50,000 paid-up share capital of Y would also be payable. Effectively, the overall tax rate of nonresident X's holding company would equal about 7% in start-up year 1989. In 1990 the taxes payable would drop to only $620, for an effective tax rate of only 0.62%, assuming no additional stamp transfer taxes were incurred.

Bank in Liechtenstein (BIL)

Liechtenstein's banks are smallish by international standards, and tend to be overshadowed by the Principality's specialized business in trusts and domiciliary companies. Outside the small National Bank there are just three banks in Liechtenstein you can contact. The oldest is Lichtensteinische Landesbank founded in 1861. Landesbank , however was recently acquired by the Bank in Liechtenstein - or BIL for short. BIL was founded in 1920.

BIL has approximately US$3.8 billion dollars on its balance sheet. Top management is cosmopolitan, consisting of board members from First Austrian Bank and Bank Leu in Zurich. Chairman of the Board Christian Norgren is from the Wallenberg Empire in Sweden. BIL's Paris branch boasts Prince Phillip of Liechtenstein as the vice-chairman. Prince Phillip's presence highlights the fact that BIL has one voting shareholder - a Foundation for the Royal Family's assets.

According to Reinhard Schmolz, chief executive officer of BIL (UK), there is a grand total of SFr 340 billion (or US$210 billion dollars ) in funds being managed by BIL. The true figure has never been made public. BIL has offices in Hong Kong, Cayman, New York, Rio de Janeiro, Frankfurt, Lugano, Zurich, Geneva and London. Its overseas staff has increased by about 320 in the past three years.

BIL is a subsidiary of the Prince Franz Joseph II Von und zu Liechtenstein Foundation . Guided by a formidable board of trustees, including Dr. Alfred Herrhausen of Deutsche Bank (Germany's largest). BIL has convinced many of Europe's millionaires to invest their money with them, making BIL's private client portfolio management department one of the largest in the world.

Bank secrecy and confidentiality of one's financial affairs are so guarded in this community that Professor Naylor publisher of " Hot Money " has alleged that various foreign secret services and criminal groups are using the tiny territory for their money laundering. While screening out spies and undesirables may be a difficult task for Liechtenstein's little government, legitimate tax planners financiers can rest assured that Liechtenstein's landlords aim to keep a respectable image. According to Prince Hans Adam, Liechtenstein's Regent , a 1980 revised company law now requires that "any commercial enterprise administering trusts or investments funds, to have qualified mangers and auditors which requires a government license to operate."

For Americans, landlocked Liechtenstein is only slightly less accessible than the Bahamas, Bermuda and Cayman Islands. The northern border touches the international railway between Basel and Innsbruck while the highway from Switzerland to Austria leads right through Vaduz. Zurich's airport is only one hour away by highway.

If you travel by train you should depart at the Swiss border town of Buchs and take one of the frequent yellow PYY coaches to Vaduz. The journey takes about 20 minutes less than if you go through the other Swiss station at Sargans, or Feldkirch in Austria. Vaduz has no taxicabs and no major hotels, but there are about 200 first-class beds available, including 30 at the grand old Vaduzer Hof . If you're looking for a place to put your money where taxes are low, you should take a trip to pint sized Liechtenstein and explore the possibilities.
(Courtesy of New Providence Press: Tax Havens of the World ).

Find the contact names, addresses, numbers and information for local government offices, banks, accountants, company formation services, investment and management companies, advisors, experts, maildrops, real estate agents and other useful local contacts in the THE OFFSHORE MANUAL & DIRECTORY .

22.33 LUXEMBOURG

Offshore holding companies in Belgium, Netherlands or Luxembourg?

A holding company is a corporation that for the most part owns shares (stock) in other related (i.e., subsidiaries) and unrelated corporations. When international tax planners talk to offshore holding companies they most often mean companies incorporated in a no or low tax jurisdiction like Panama, Gibraltar, Barbados, Bermuda, the Bahamas or the Cayman Islands where stock holdings in other companies can be sold free of capital gains taxes, and dividends and interests received are free from local incorporate taxation.

Be what it may, a number of high tax countries in Western Europe have adopted corporate tax laws that offer significant tax advantages to holding companies that register within their territorial borders. The Netherlands, Luxembourg and Belgium make excellent domiciles for offshore finance and investment holding companies that invest in other companies domiciled in other high tax jurisdictions such as the U.S., UK, Canada and Germany. In addition to significant tax breaks for dividends and capital gains received on such stock participation, the Netherlands, Luxembourg and Belgium have important bilateral tax treaties with the other industrial countries (including the U.S., Canada, the UK, Germany Australia) that reduce or eliminate withholding taxes on interest, dividends and royalties received by these holding companies.

Dutch "Participation Exemption"

Under the Netherlands tax code, a Dutch "holding company" that owns "at least 5%" of the par value of the paid-in capital in another foreign or domestic company from the beginning of the fiscal year can receive dividend distributions from this "subsidiary" 100% tax free. To qualify for the so called "participation exemption", the "downstream subsidiary" must meet the following conditions:

1. In the case of a foreign subsidiary the company must be subject to a corporate income tax comparable to the Netherlands corporate tax, but the rate and amount of corporate tax paid is immaterial.

2. The "participation" in the foreign subsidiary must be held for a business-related purpose, not as a mere "portfolio" investment. In this respect, if the Dutch parent company has a director on the board, or is actively engaged in the supervision of the subsidiary, than the company will qualify for the participation exemption provided the foreign subsidiary is not directly or indirectly merely an investment company.

Treaty Benefits for Dutch Finance Companies

Combining the Dutch Participation Exemption with the treaty benefits can and does lead to substantial tax savings for Dutch based holding companies. Under the U.S.-Netherlands tax treaty the 30% U.S. interest withholding tax is reduced to 0%. Moreover, under the Dutch tax system no interest withholding taxes on payments made to any nation (even to tax haven companies) are imposed on any Netherlands company because interest withholding taxes are unknown in the Netherlands. Because Holland maintains a net-work of tax treaties with many industrial nations that reduce significantly interest withholding taxes, the Netherlands make a first-rate base for the formation of an international bank, holding company or finance company. Other benefits of the participation exemption include:
  1. The willingness of the Netherlands corporate tax inspector to grant special tax rulings in favor of Netherlands based finance companies.
  2. Interest payments made to foreigners are fully deductible when computing Dutch corporate income taxes so long as the payment is made at "arms length". Usually the Dutch corporate
income tax inspector will "fix" the net taxable income of the company at a certain percentage of the total outstanding debt, or require that a certain "interest spread" between interest received and interest paid-out be used to calculate the tax. A " spread ruling " from the tax inspector of 1/8% or ¼% can usually be " negotiated " by the tax advisor.

3. So called "back-to-back loan arrangements" between a Dutch company and a tax haven entity are common and not looked on unfavorably by the Dutch tax authorities.

It's not surprising that by years-end 1987 the Netherlands with some $48 billion in U.S. investments could claim the second highest direct investments in the U.S., surpassing Japan's $32 billion, Canada's $22 billion, West Germany's $19 billion, and Switzerland $14 billion, and trailing only the United Kingdom's $76 billion investments in the USA.

Belgium's new "Participation Exemption"

Belgian holding companies that hold a participation in other companies can exempt 95% of any dividend received from such companies provided the other company is not located in a country that (1) does not tax corporate income or (2) which has a tax regime, which is substantially more favorable than that in Belgium.

In addition, capital gains from the disposition of participation shares are 100% tax free from the 1992 tax year onward.

Editor's Note : Unlike the participation exemption in the Netherlands, there is no minimum holding period and no minimum participation to qualify for the Belgian participation exemption.

The Belgian participation exemption does not apply if:

1. The dividends are distributed by companies, which are not subject to taxation similar to Belgian corporate income tax. This includes no-tax jurisdictions:
  1. Andorra
  2. Anguilla
  3. Bahamas
  4. Bahrain
  5. Bermuda
  6. Campione
  7. Cayman Islands
  8. Grenada
  9. Nauru
  10. Saint-Pierre-et-Miquelon
  11. Sark
  12. Tonga
  13. Turks & Caicos
  14. Vanuatu
Also excluded from the participation exemption are IBC's in Jamaica, Barbados, Antigua and the British Virgin Islands and exempt companies in Gibraltar, and the Isle of Man. Also included are holding companies in Liechtenstein, Luxembourg and shipping companies based in Cyprus and Malta. In addition, countries that do not tax foreign source income - Panama, Singapore, Hong Kong, Costa Rica, the Cook Islands, Djibouti, Malaysia, Nevis and Oman.

2. Dividends distributed by a mere investment company.

Interest expenses are fully deductible

The Belgian corporate tax rate is 39%, and companies are taxed on their worldwide income. Since finance charges on loans (mainly interest) incurred to purchase the participation are deductible by the Belgium parent company, tax planning revolves around incurring the least amount of taxable income possible.

Tax treaties & withholding taxes

No Belgian withholding tax is due on (1) interest on commercial debts (including debts evidenced by commercial documents) and (2) interest paid by banks established in Belgium to foreign banks. Dividends paid by a Belgian company to a nonresident individual or corporation is subject to a 25% withholding tax unless reduced by a tax treaty. Under the treaty with the U.S., dividend withholding is reduced to 5% or 15%.

Withholding taxes on dividends paid by a U.S. company to a Belgian company that owns a substantial holding in the U.S. Company is reduced to 5%. Royalties are 100% free from U.S. withholding tax unless they are film and television royalties in which case the full 30% U.S. withholding tax applies. U.S. interest withholding tax is reduced to 15% under the Belgium-U.S. tax treaty.

Luxembourg's Participation Exemption

Luxembourg has been famous as a domicile for holding companies since 1929 when the Grand Duchy of Luxembourg abolished all income taxes and applied only a 0.2% annual subscription tax on share capital and a capital duty of 1% payable on this issue of new shares. However, Luxembourg holding companies that qualify for the above tax exemption do not qualify for any treaty benefit that Luxembourg concluded with other nations. Recently, to increase Luxembourg's attractiveness as a business and financial center, the Luxembourg government passed a law extending Luxembourg's participation exemption, which already existed for dividends, to capital gains if the company, would be subject to Luxembourg's normal corporate tax regime (i.e., companies not exempt from tax under the 1929 Law). For 1991, Luxembourg's national and municipal corporate tax rate is approximately 39%.

The participation exemption exempts cash dividends, dividends-in-kind, hidden profit distributions, capital gains on liquidation distributions, and capital gains on the sale of the qualifying subsidiary.

To qualify for the participation exemption and the tax treaty benefits the following conditions must be met.

(1) The parent company must be a resident and fully taxable in Luxembourg.
(2) For dividends to be exempted, the participation in the foreign subsidiary must equal at least 10% of the subsidiary´s share capital or have an acquisition cost at least LF 50 million.

(3) The participation must be held for an uninterrupted period of 12 month prior to the end of the taxable year in which the dividend is received.

(4) For capital gains to be exempted, the shareholding in the foreign subsidiary must equal at least 25% of the subsidiary´s share capital or have an acquisition cost at least LF 250 million.

(5) To qualify for the participation exemption on dividends and capital gains, the nonresident subsidiary must be subject to corporate tax in its home country at a rate of at least 15%. The exemption covers corporate income and wealth tax as well as municipal and local taxes.

Interest expenses are deductible

Interest paid on a loan to purchase a qualifying participation is deductible to the extent it exceeds the tax-free dividends and gains. Luxembourg does not levy an interest withholding tax on interest paid to a foreign person, and there are no debt/equity ratio rules. Ratios as high as 33:1 are acceptable by the tax authorities. A Luxembourg company may be collapsed without any tax consequences, and there is no capital gains tax on the disposal of shares in a Luxembourg corporation by a foreign person.

Tax Treaties & withholding taxes

Luxembourg has tax treaties with Austria, Belgium the U.S., France, Germany, the Netherlands, Spain, Sweden, Norway and the UK. Under the treaty with the U.S., Luxembourg's dividend withholding tax on portfolio investments paid to a U.S. resident is 7,5%, and reduced to 5% on substantial holdings where the recipient corporation owns at least 25% of the Luxembourg company's voting stock.

The U.S. dividend withholding rate is reduced from 30% to 15% on portfolio investments, and to 5% on substantial holdings. U.S. interest withholding tax is reduced to 0% if the Luxembourg Company is subject to Luxembourg's regular corporate income tax.
(Courtesy of New Providence Press: Tax Havens of the World ).

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22.34 MADEIRA

Incorporation of Portuguese companies is the preserve of the legal profession and is an extremely lengthy and bureaucratic process. Firstly, name approval has to be obtained from a Central Registry not known for flexibility nor speed of processing applications. Once this has been obtained, the proposed share capital of the company (minimum Esc 400,000.00) must be deposited with a bank in an account opened in the name of the proposed company. The articles of association of the company must be drafted and signed by the shareholder(s) by way of a deed before a public notary following which registration with the local Finance (Tax) Department and Social Security office must be made. Within 90 days of the date of the deed of incorporation the company must be registered at the local Kommerciel Registry Office followed by publication of the articles of association in the Government Gazette and a local newspaper. The official books of the company must also be registered with the local tax department and the commercial Registry.
As can be seen this is a lengthy and tortuous process which can delay the start of business activity by several weeks or longer.

MADEIRA OFFSHORE ZONE

The beautiful island of Madeira is situated about 700 kms west of the coast of north west Africa on the same latitude as Casablanca, Morocco. It was discovered by Portuguese seafarers in the XV century and has remained Portuguese territory ever since. Due to the political changes in Portugal in the mid 70's Madeira has become an autonomous region with its own Parliament and locally elected Government, however it remains legally and politically part of Portugal and is thus a full member of the European Union .
Legislation implemented by the Portuguese government with the aim of "kick starting" the island's economy makes it one of the most effective tax free corporate vehicles in the world today. Recognized by most EU countries as being a development area and not purely a tax haven and with the advantage of full access to the Portuguese tax treaty network, Madeira registered companies are often the perfect vehicle for investment by non-EU individuals into Europe and particularly for trading within the European Union, where a Value Added Tax (VAT) registration number is required.

Portugal currently has tax treaty agreements with Austria , Belgium, Brazil, Denmark, Finland, France, Germany, Italy, Japan, Mozambique, Norway, Spain, Switzerland and the United Kingdom . The terms of these treaties provide, amongst other things, that payments of dividends and royalties from these countries can be made with a much lower rate of tax being withheld at source. For example, royalties being paid by a U.K. company to a non-resident corporation or individual would normally be subject to a withholding tax of 25%. However, if those same royalties are paid to a Madeira company the rate of withholding tax may be reduced to 10% by virtue of the provisions of the U.K./ Portugal tax treaty. This is despite the fact that those same royalties would not be subject to tax on arrival within the accounts of the Madeira company and would also avoid any withholding tax when remitted from the Madeira company to the eventual beneficiary.

In addition to the normal offshore company, Madeira also allows for the incorporation of the SGPS (Sociedades Gestoras de Participatoes Sociais). The SGPS has been specifically designed to take advantage of European Union Directive 90/435. The terms of that Directive require that dividends paid by a subsidiary located in one EU state to a parent company located in another EU state must not be subject to any form of withholding tax as long as certain conditions are met - the most important of which is that the parent company cannot be exempt from taxation in its country of incorporation. The SGPS is therefore subject to a rate of tax of 36% on dividends received from subsidiaries situated in other EU states but 95% of the dividend income is exempt from taxation. Thus, the effective rate of taxation on dividends is 1.8% only. The SGPS must not undertake activities other than holding shares in other companies. This type of company is therefore of considerable use to any company located outside the EU which wishes to invest within the EU.

As can be seen the Madeira corporate entry deserves special attention either as a holding company or for trading by a non EU entity with or within the Union.
With the offshore world booming at the moment many countries such as Malta, and the Canaries have jumped on the bandwagon to attract new and lucrative business however for some time Madeira has been the leader of the Southern European pack. Being an integral part of Portugal Madeira benefits from Portugal's double tax treaties and EU directives, such as 90/435, which makes it an ideal conduit for European investment. Because few treaty partners make a distinction between mainland Portugal and Madeira it is under certain treaties for 'tax credits' will be available since the Madeiran company will be deemed to be liable to full Portuguese tax. The Standard Madeiran Holding Company, or SGPS, benefits from Portugal's tax treaties and EU directives and it does not, like other Madeiran undertakings, have to be licensed or located in the International Business Center. Whilst the activities of the SGPS are limited to investments the advantages are significant: dividend income arising to the SGPS from EU investments is taxed at 1.8%, no Portuguese withholding taxes (normally 25%) are levied on dividend distributions; where dividends are received from investments made in companies incorporated outside oofthe EU; no taxes, including the 1.8% will be payable and all other income, provided it is within the proscribed parameters will be taxed on the same basis as all other Portuguese at a rate of 1.8%.
(Courtesy of the Baltic Banking Group).

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22.35 MALAYSIA

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22.36 MALTA

Find the contact names, addresses, numbers and information for local government offices, banks, accountants, company formation services, investment and management companies, advisors, experts, maildrops, real estate agents and other useful local contacts in the THE OFFSHORE MANUAL & DIRECTORY .