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FAQ FOR OFFSHORE INVESTORS AND EXPATRIATES
LINKS IN THIS SECTION RELATED INFORMATION
  OFFSHORE INVESTMENT & TAXATION
GENERAL OFFSHORE BANKING
PRIVATE BANKING FOR HIGH NET WORTH INDIVIDUALS
OFFSHORE MUTUAL & INVESTMENT FUNDS
OFFSHORE EQUITIES
OFFSHORE PENSIONS
INTRODUCTION TO ALTERNATIVE INVESTMENT
A GUIDE TO ALTERNATIVE INVESTMENT
REGULATION OF ALTERNATIVE INVESTMENT
OFFSHORE INFORMATION PROVIDERS
DIY INVESTMENT
 



In France, tax is due on world-wide income, whether from investments or earnings, when an individual is deemed to be tax resident. Non-residents are taxed only on French source income and assets. Tax residency is assumed if the individual has a home in France, if it is their principal abode, if it is the centre of their economic interests, or if their principal professional activities are performed there.

Establishing non-residence for a French tax resident usually amounts to demonstrating that residence has been established elsewhere, and that the normal tests for French residence are not fulfilled. Clearly this is not easy, and it can often happen that a French expatriate has dual tax-residence, at least for a period - Double Tax Treaties, where they exist, usually sort this out, but it is important for an expatriate French national (or a tax-resident for that matter) not to incur tax on foreign income in a country without a French Double Tax Treaty (ie most offshore jurisdictions).

As from July, 2005, France provides information about the returns on savings paid to citizens of other EU Member States to the citizen's home state, under the EU Savings Tax Directive.

There are gift and inheritance taxes in France which are not easily escaped, although within a family the rates are quite low. If a non-resident legatee has been a resident of France for six out of the previous ten years, the tax applies to worldwide assets transmitted, regardless of the residence status of the deceased.

Once a French citizen has established non-residence, no French income tax will be payable on foreign interest income, even if it is repatriated to France - but the annual wealth tax (levied on a sliding scale) will bite on any assets accumulating in France.



There are over 500 major banking institutions in Switzerland, and it is estimated that more than 35% of the worlds private wealth is centred there. It is a low tax rather than offshore jurisdiction as such, and has earned a reputation for neutrality and security, conservative financial policies, and stringent banking secrecy (with limited exceptions in line with its legislation on combatting money laundering activity). Banks and financial institutions are regulated by the Federal Banking Commission, which applies world standard equity, capital, and liquidity rules to them.

There is no centralized taxation system in Switzerland, due to its federal nature, and because of this, some taxes are levied at a federal level, and some at a communal or cantonal level. Residence is assumed if an individual is in Swiss employment, owns a business in Switzerland, or spends more than 180 days in any one tax year there.

Residents are taxed on their world-wide income up to a maximum of 11.5% at a federal level, and approximately twice that at a cantonal level (although in December, 2007, the Swiss canton of Obwalden became the first canton to adopt a flat rate of tax for individual income taxpayers, following a cantonal referendum), and non-residents are liable for tax on income arising from permanent Swiss establishments and real estate. There is also a ‘fiscal deal’ available for High Net Worth Individuals who are considering making Switzerland their home, but are not intending to work there.

There is a double tax treaty in place between Switzerland and France whereby full withholding tax is deducted at source, but a partial or full refund can be claimed from the Swiss tax authorities. It is worth noting, however that in recent years Switzerland as a financial centre has moved away from smaller individual client accounts, to focus on providing more sophisticated services for larger professional clients.

As from July, 2005, Switzerland applies a withholding tax of 15% to the returns on savings paid to citizens of EU Member States, under the EU Savings Tax Directive.

It will be seen that Switzerland is not a suitable place in which to deposit money if the goal is to obtain tax-free interest payments on behalf of a non-resident.



Although private banking for rich Monagesque residents was the original basis of the Principality's banking sector, this has changed. Many factors have contributed to Monaco's rise as a banking centre in the last 10 or so years, including the presence of a secure legislative base (the Bank of France is responsible for regulatory oversight), the absence of withholding tax on interest payments, and a rush of Italians away from their ever-tighter domestic tax regime.

There are now some 70 banks and financial institutions in Monaco, with more than 300,000 accounts (remember that there are 5,000 Monagesque nationals, and another 25,000 foreign residents). Approximately 85% of the banks' customers are non-resident. Banking turnover is in excess of $1.5bn, and assets under management top $60bn.

Although there is no capital gains or income tax, (which means that residence or otherwise is not really an issue) French nationals who work in Monaco are liable to pay social contributions of around 40% on their salaries. Monaco has only one taxation treaty, with France, but this is not a double tax treaty in the accepted sense of the word, as it merely provides for income tax to be levied against French nationals who transfer their residence to Monaco.

Banking facilities in Monaco are well adapted to the needs of expatriates and offshore investors, with a wide range of depositary services on offer. Secrecy is adequate for individuals with no French connections, but somewhat compromised for French residents.

As from July, 2005, Monaco applies a withholding tax of 15% to the returns on savings paid to citizens of EU Member States, under the EU Savings Tax Directive.




Liechtenstein has a substantial banking sector, regulated under the Law on Banks and Finance Companies of 1993. The currency is the Swiss franc (as the jurisdiction has a customs and monetary union with Switzerland), and there are no exchange controls.

Liechtenstein used to be known for particularly stringent banking secrecy, but after the events of 2000 the "know your customer" system became legally compulsory (from 1 October, 2000) for all banks that belong to the Lichtenstein Bankers' Association.

Residency is assumed if an individual maintains a residence with the intention of remaining on a more than temporary basis, or performs some kind of employment or activity for gain in Lichtenstein. For resident individuals, income tax is charged at up to 18%, with a net worth tax of around 0.9% (depending on the commune of residency), although there is no separate capital gains tax. Non-residents are taxed only on Lichtenstein sourced income. Only one double taxation treaty has been established, with Austria.

Withholding (Coupon) Tax is levied on any distribution of dividends or profit shares (including distributions in the form of shares). Generally, there is no withholding tax on interest or royalty payments, but it does apply to interest from bonds, to interest from time deposits with domestic banks in excess of 12 months, and to interest on some commercial loans over SFr 50,000 with a minimum term over 2 years.

Deposits can be made in all the main currencies and interest rates follow European norms.

As from July, 2005, Liechtenstein applies a withholding tax of 15% to the returns on savings paid to citizens of EU Member States, under the EU Savings Tax Directive.


LINKS IN THIS SECTION RELATED INFORMATION
  OFFSHORE INVESTMENT & TAXATION
GENERAL OFFSHORE BANKING
PRIVATE BANKING FOR HIGH NET WORTH INDIVIDUALS
OFFSHORE MUTUAL & INVESTMENT FUNDS
OFFSHORE EQUITIES
OFFSHORE PENSIONS
INTRODUCTION TO ALTERNATIVE INVESTMENT
A GUIDE TO ALTERNATIVE INVESTMENT
REGULATION OF ALTERNATIVE INVESTMENT
OFFSHORE INFORMATION PROVIDERS
DIY INVESTMENT
 

 

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