SOLUTIONS

WHAT WE PROVIDE

For an ever-changing financial world we provide high quality financial services and products to a wide range of clients. We do this by ensuring we continually develop our knowledge through reference to experienced and industry leading professionals. We keep abreast of international developments and offer innovative and efficient products and services tailored to client’s ever changing needs that are regularly reviewed for optimal effectiveness. 

 

We align ourselves and work with blue-chip partners globally ensuring the highest standards of quality are maintained. 

FINANCIAL SOLUTIONS

We offer a wide range of financial solutions and services for our clients. We can negotiate with, and source from banks large capital and trade finance projects for and on behalf of our clients. Where appropriate, we can facilitate and advise on effective currency hedge initatives for clients exposed to large fluctuations in their trading and home currencies. 

 

Using an intermediate finance company we are able to assist clients re-capitalise funds back into their local jurisdiction through a number of mechanisms, including capital contribution or commercial loan arrangements. 

IP & ROYALTY SOLUTIONS

Royalty structures are intended to provide tax efficient licensing routes that enable, among other benefits, reduced withholding taxes and corporate income taxation on royalty payments. The structure will connect the IP owner, the licensee and sub licensee in jurisdictions where local tax laws combine with double tax treaties to greatly reduce the overall tax burden. 

 

Setting up the IP owner in a no or low tax jurisdiction coupled with the registration of the license entity in a jurisdiction with a wide network of double tax treaties will ensure a robust and tax efficient structure. 

 

Contact our international tax team for more information. 

INVESTMENT VEHICLE SOLUTIONS

When making investments, whether it be for tangible or intangible assets, it is important the correct investment vehicle is used. Vehicles like limited liability partnerships (LLP’s) provide excellent tax deferral vehicles whereby profits are taxed not at an entity level but by the level of the partners or members. As the name suggests the partners or members are only liable for the capital introduced to the vehicle which differs from standard partnerships. 

 

Provided certain conditions are met -e.g partners or members are not local tax residents and there are no locally held assets or income generated, the entity will not be taxed on the income or capital gains made. Only once profits are distributed will the individual partners or members be liable for taxes in their home jurisdictions. 

 

Many jurisdictions have introduced this type of vehicle as a method of encouraging foreign investment. 

HOLDING COMPANY SOLUTIONS

The location of a holding company is an important consideration when optimizing tax charged on international income flows and capital gains. Ideally the holding company would be resident in a jurisdiction which has a number of key features including: 

 

* Extensive double tax treaty network. 

* Exemption on dividend income. 

* Exemption from capital gains on disposal. 

* No duties on share capital. 

* Exemption from withholding tax on distributions. 

 

To find out more about which jurisdiction would best suit your needs or to enquire about holding company incorporation contact our international tax team.