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Globe-Trotting
Sportsman Or Entertainer: Dubai
A
UAE citizen or resident with extensive,
international, multi-sourced income is
not subject to personal taxation in Dubai,
although the peripatetic professional
may well find herself paying withholding
tax in a number of countries which cannot
in some cases be reclaimed because of
the absence of a tax treaty.
Dubai
does in fact have double tax treaties
with 47 countries, and income earned in
those countries may escape withholding
tax under a treaty.
Sportsmen
and entertainers receiving income in Dubai
will not be subject to withholding tax.
American
citizens, and nationals of the very few
other countries that tax world-wide income
on the basis of citizenship, won't be
able to take advantage of the low-tax
environment in Dubai, but for all other
nationals, it is available.
In
choosing between various types of offshore
asset for investment purposes, the main
consideration for a Dubai-based individual
will be his or her intended residential
plans following departure from Dubai.
If the plan is to move on on to another
offshore jurisdiction, then investment
choices will not be much constrained,
but if the plan is to return to a high-tax
jurisdiction, then it is vital to study
the anti-avoidance legislation of that
jurisdiction before acquiring offshore
assets. Some jurisdictions tax offshore
assets more severely than domestic assets
and 'look through' trust arrangements,
while others accept trust assets as being
outwith the tax net.
Equally,
if it is planned to return to a high-tax
jurisdiction, almost all of which tax
world-wide income, then plans must be
made to shelter income insofar as this
is possible, by using trusts or other
tax-distancing vehicles, if this is practicable
within the tax regime of the chosen jurisdiction.
The UK offers a special regime which may
be helpful (select 'Globe-trotting Sportsman
or Entertainer' and 'UK').
If
the eventual residential jurisdiction
is one of those that has a very restrictive
tax regime, then individuals falling under
this heading may need to resort to corporate
structures to market their skills and
manage derivative income flows. It may
well be that these can usefully be based
in offshore jurisdictions, although complex
structures may be necessary if corporate
anti-avoidance rules are to be avoided.
www.lowtax.net
contains details of the corporate and
individual tax regimes for 50 offshore
jurisdictions.
NB: The suggestions given above do not
constitute investment advice. They are intended
only to assist individuals in finding appropriate
professional advice, which is essential
for anyone planning offshore investment.
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