BAHAMAS
Language - English
Currency - Bahamian Dollar
Status - Independent Commonwealth State
Population - 310,000 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| N/A
|
N/A
|
N/A
|
Levied
annually on market value of real estate:
Owner-occupied:
1% for value between BSD100,000 and BSD500,000; 1.5% over that.
Unimproved:
BSD30 if value is less than BSD3,000; 1% for value between BSD3,000
and BSD100,000; 1.5% over that.
Other:
1% if value is up to BSD500,000 and 2% over that.
|
| STAMP
DUTY |
OTHER
TAXES |
TAX
RESIDENCE QUALIFICATION |
BASIS
OF RESIDENT TAXATION |
| From
4% to 12% |
Payroll
taxes (employer); Business Licence fees |
N/A
|
National
Insurance and events based taxation |
| LEGAL
BASIS OF RESIDENCE |
COST
OF RESIDENCE DOCUMENT |
WORK
PERMIT REQUIRED? |
WORK
PERMIT AUTHORITY |
| Home
owners and major international investors |
Annual
Residence: $1,000, Permanent Residence: $5,000 |
Yes
|
Department
of Immigration |
Bahamas
From a banking and investing point of view, the Bahamas are a well-respected
jurisdiction; the banking environment is stable, the secrecy laws stringent,
and the investment environment sophisticated. Banking secrecy may however
be under threat from new legislation, as a result of international pressure.
The main areas of expertise in the islands are:
- Trust formation and management
- Mutual fund management
- Banking. The Bahamas is one of the world's top ten banking centres,
and there are more than 300 banks (representing over 30 countries).
The banking industry is stringently regulated by the Central Bank of
the Bahamas.
Exchange controls apply only to the Bahamian dollar, and to resident
individuals and companies, and there is no income tax, capital gains tax,
purchase or sales tax, VAT or capital transfer tax. As a result, length
or frequency of residence in the Bahamas does not affect tax liability.
Taxation consists of social insurance contributions, Business License
fees, stamp duty on property transactions, annual property tax, and some
quite high customs duties.
Although foreign investment in local real estate or enterprise is positively
encouraged in the Bahamas, obtaining long-term residence and/or employment
on the islands is somewhat more difficult, although not impossible. One
way of securing residence is to obtain a Home Owners Residence Card, which
must be renewed annually, and acts as both visa and residence permit for
the duration. (Strangely, the applications of immigrants in possession
of, or looking to buy, local property valued at $500,000 or more receive
accelerated consideration!)
Anyone seeking to obtain annual residence privileges should expect to
pay around $1,000 per year (with another $20 payable per dependent), while
the head of a household seeking permanent residence will pay approximately
$5,000.
A non-Bahamian looking to work on the islands must obtain a work permit
(each one being valid for that specific person and position), but this
is far from easy. In the case of senior executives, or those possessing
special skills not available in the Bahamas, the process is accelerated;
other foreign nationals need to be assessed by the Immigration Board (to
ascertain their usefulness to the Bahamian community and economy), and
their prospective employer must obtain a certificate from the Labour Exchange
to the effect that the job was advertised and interviewed for locally,
and there was no equally qualified Bahamian available to fill the position.
Only then will the issuance of a work permit be considered.
The lifestyle offered by the Bahamas for the resident/retired expat is
an enviable one, however, with the tropical maritime climate making pursuits
such as sailing, swimming, snorkelling and golf popular and enjoyable.
The official language of the islands is English, and there are a number
of English language newspapers available, although Creole is also widely
spoken. The population of the Bahamas is predominantly Christian.
Finally, although the lack of income tax and tax on investment, coupled
with the burgeoning reputation of the islands (in particular Nassau) make
it an attractive destination for possible future residence or retirement,
do bear in mind the import duties (which are very high), and can sometimes
be forgotten when making this kind of decision. Although you will not
be taxed on income or investment gains, you will not be living 'tax-free',
by any standards, so this jurisdiction is perhaps more suitable for those
expatriates with a substantial net worth.
For a more detailed treatment of the tax and legal regimes in this and
35 other offshore jurisdictions, please visit the Lowtax
Jurisdictions Guide.
CAYMAN ISLANDS
Language - English
Currency - Cayman Islands Dollar
Status - UK dependent territory
Population - 50,200 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| N/A
|
N/A
|
N/A
|
Real
estate transfers are charged stamp duty at between 4% and 7.5%. |
| STAMP
DUTY |
OTHER
TAXES |
TAX
RESIDENCE QUALIFICATION |
BASIS
OF RESIDENT TAXATION |
| Up
to 1.5% on legal documents dealing with valuable assets or transactions
|
Import
duties |
N/A
|
Stamp
duty and import tax |
| LEGAL
BASIS OF RESIDENCE |
COST
OF RESIDENCE DOCUMENT |
WORK
PERMIT REQUIRED? |
WORK
PERMIT AUTHORITY |
| Residence
Permit (granted on quota basis) |
N/A
|
Yes
: cost varies widely |
Immigration
Board |
Cayman Islands
The Cayman Islands are one of the premier offshore financial
centres, but have something of a reputation as a stereotypical 'tax haven'
in Europe, although they have been attempting to guard against money laundering
practices. It has to be said, however, that in the absence of proven wrongdoing,
the emphasis is still firmly on preserving confidentiality. (Although
this was dealt a blow by the judgement awarded in 2002 to the US Internal
revenue Service in Miami, allowing them access to American Express and
MasterCard records covering US citizens with offshore assets in the Caymans.)
As with some other Caribbean jurisdictions, recent international pressure
is leading to new legislation in this area.
Although the jurisdiction is well suited to the majority of offshore
enterprises, particular specialities are banking, captive insurance, trust
formation and management. Mutual funds are also a growing sector since
the establishment of the Cayman Islands Stock Exchange in 1997. There
are nearly 87,230 active corporations registered on the island (2007),
and nearly 300 banks, which are regulated by the independent Cayman Monetary
Authority. Banking assets exceed USD1.8 trillion (2009). The regulatory
regime is in accordance with the Basle Committee regulations.
There are no direct taxes levied in the Cayman Islands, with government
revenue coming from customs duties, stamp duty and registration fees levied
on corporations. There are no exchange controls, and the islands are exceptionally
politically stable.
Caymanian residency has traditionally been granted on a quota basis to
citizens from countries including the UK and British dependencies, Ireland,
Australia, New Zealand and the US. An expat applying for permanent residence
(without permission to work) will have had to prove that they have sufficient
financial resources to support themselves and their families, and to invest
at least USD180,000 in local enterprise or real estate. Permits have initially
been valid for six months, but at any point after that, the expatriate
could apply to have the status changed to permanent resident. A deposit
must also be provided against possible future repatriation costs, and
the amount varies depending on country of origin.
After two years of permanent residence, a foreign national wanting to
seek employment can usually apply for a work permit. These are usually
limited to a specified area of employment, and are generally issued for
2-3 years for senior positions. Work permit charges are payable, (which
vary widely according to the position applied for, and, to some extent,
the island on which the employment is located) and the employer must put
up the possible repatriation deposit.
In January 2007, amendments revising the Cayman Islands Immigration Law
(2006 Revision) came into force. The Law contains a number of changes
to the Immigration Law, 2003, including work-permit term limits, permanent
residency, a new category of 'key employees' and the ability of the Chief
Immigration Officer to grant Caymanian Status to certain categories of
applicants. The new law sought to clarify the work permit rules after
years of frequent change to the rules, resulting in confusion for employers
and backlogs in the processing of work permit applications.
Cayman Finance - the body that is representative of the islands' financial
services industry - has welcomed proposed amendments to immigration laws,
announced by Cayman Prime Minister McKeeva Bush in Janaury 2010, drafted
to encourage foreign financial services companies to remain in the jurisdiction.
Making the announcement, Bush said that the government was fast tracking
legislation to ease immigration laws imposed on those employed in the
financial services sector. Under the proposed legislation, foreigners
will be allowed to the island for extended periods, and the amount of
time that they are required to reside outside of the territory after the
expiry of their permit will be reduced.
In a statement welcoming the decision, Cayman Finance said that it "fully
endorses the positive steps the government is taking to strengthen the
Cayman economy and its financial services industry in these more challenging
economic times."
The concept of tax residence is not applicable in the Cayman Islands
due to the lack of direct taxation.
English and Spanish are widely spoken on the islands, and there are a
few English language newspapers available. The climate is warm and tropical,
and pastimes such as scuba diving (which is said to have originated in
the Cayman Islands), motor sports, and golf are widely enjoyed. The islands
are predominantly Presbyterian, although there are also Anglican communities,
and Jehovah's Witnesses.
The cost of living is relatively high (due to the fact that the majority
of goods are imported), but the absence of direct taxation should offset
at least some of this. The overall standard of living is high, and whether
as a base for investment during your working life, a temporary residence,
or a possible future retirement destination, the Cayman Islands are an
attractive option.
For a more detailed treatment of the tax and legal regimes in this and
40 other offshore jurisdictions, please visit the Lowtax
Jurisdictions Guide.
CYPRUS
Language -
Greek and English; Turkish in the north
Currency -
Euro (Turkish Lira in North)
Status -
Independent Sovereign Republic (Turkish area refers to itself as
Turkish Republic of Northern Cyprus)
Population - 1.1m |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
Nil to EUR19,500; then 20% to EUR28,000;
25% to EUR36,000; 30% after that; foreign pension income is taxed
at 5%.
|
N/A
|
20%
capital gains tax (except on sale of real estate by non-residents) |
0%
up to EUR170,860 but based on 1980 values. The following ratio applies
thereafter: from EUR170,860 and up to EUR427,150 - 2.5:1,000; from
EUR427,150 and up to EUR854,301 - 3.5:1,000; and over EUR854,301
- 4:1,000. |
| STAMP
DUTY |
OTHER
TAXES |
TAX
RESIDENCE QUALIFICATION |
BASIS
OF RESIDENT TAXATION |
| N/A
|
N/A
|
Present
for more than 183 days |
World-wide
income |
| LEGAL
BASIS OF RESIDENCE |
COST
OF RESIDENCE DOCUMENT |
WORK
PERMIT REQUIRED? |
WORK
PERMIT AUTHORITY |
| Residence
Permit; Cyprus is now a member state of the EU |
N/A
|
Yes
for non EU or EEA residents: TRE permit |
Civil
Registry and Migration Department |
Cyprus
Cyprus is well known for its financial sector, with the
primary focus and expertise being in the formation and management of holding,
investment, and trading companies. These are a draw for foreign investors
in part because of the many double taxation treaties established between
Cyprus and other high tax countries, and in part because of the 10% corporate
tax regime; the lowest in the EU. There is also a thriving shipping sector.
For pensioners, foreign investment income is charged at 5% on amounts
over EUR3,417 pa provided that the individual is neither resident nor
Cypriot, nor has economic activity on the island. Although some countries
offer more attractive withholding tax rates, very few can compete with
final taxation this low.
In addition to the Central Bank, the Cypriot banking system consists
of 4 banks listed on the Cyprus Stock Exchange, 8 subsidiaries of foreign
banks, 2 banks licenced to conduct limited banking operations, 8 branches
of banks from EU countries, 17 branches of non-EU banks, 2 Representative
Offices and 4 other banks. Since 2005, all Cyprus companies are 'onshore';
exchange controls have been abolished.
The Temporary Residence Employment (TRE) permit acts as permission to
reside and work in Cyprus, and these are categorised as executive and
non-executive permits, with the latter usually only issued if there is
no suitably qualified Cypriot available to take the position. However,
they are given fairly freely to senior employees, and foreign nationals
retiring to the island. The TRE permit, until recently, was issued initially
for a two year period, renewable at three yearly intervals subsequently.
Legislation in July 2000 required an expatriate worker to have obtained
a five year permit, or have been resident in Cyprus for five years, in
order to be able to bring their spouse and children to live with them.
However, more recent legislation (November 2000) relaxed this rule for
expatriates working in certain sectors (specifically education, foreign
media, offshore, accounting, and those who have invested more than EUR160,000
in local enterprise).
An individual is seen to be tax resident in Cyprus if he/she is present
for more than 183 days in any tax year. Non-EU or non-EEA nationals require
permits from the government to purchase property on the island, which
should be for physical residence. Citizens of EU member states are now
of course entitled to work in Cyprus without permits, but the process
can be sticky for some nationalities.
The majority of the Cypriot population (80%) speak Greek, with the remainder
in the Northern sector speaking mainly Turkish. English is also widely
spoken, with German, French and Russian being spoken in the main tourist
centres. There are several English language newspapers available, and
the warm Mediterranean climate means that pursuits such as cycling, golf,
and water sports are popular, although winter sports (in winter!) are
becoming more popular.
The predominant religion is Greek Orthodox, and it is worth bearing in
mind that although civil disorder is not common, there are tensions between
the south and the northern, Turkish controlled area of Cyprus.
The permit issued to intending retirees is usually issued for one year,
and is renewable annually thereafter, subject to proof of adequate financial
resources (i.e. capital, investment income, or pension), and expatriate
retirees are not permitted to undertake any kind of work in Cyprus except
voluntary charity work. The network of double taxation treaties means
that in most cases, retirement income remitted from abroad will not be
subject to withholding tax at source.
For a more detailed treatment of the tax and legal regimes in this and
40 other offshore jurisdictions, please visit the Lowtax
Jurisdictions Guide.
GIBRALTAR
Language - English, but Spanish widely spoken
Currency - Gibraltar Pound
Status - UK dependent territory
Population - 29,000 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| Varies
depending on whether paying tax under Allowance Based System or
Gross Income Based System (Top rate is 40%) |
N/A
|
N/A
|
N/A
|
| STAMP
DUTY |
OTHER
TAXES |
TAX
RESIDENCE QUALIFICATION |
BASIS
OF RESIDENT TAXATION |
| N/A
|
N/A
|
Present
for 183 days in tax year, or a mere visit if you have accommodation
|
World-wide
income |
| LEGAL
BASIS OF RESIDENCE |
COST
OF RESIDENCE DOCUMENT |
WORK
PERMIT REQUIRED? |
WORK
PERMIT AUTHORITY |
| Special
regimes available for 'HINWIS' and Expat Executives |
Cat
2-G£500 (Indefinite), Cat 3 or 4-G£500 (3 Year Certificate) |
Yes |
Governor
(under Control of Immigration Ordinance) |
Gibraltar
In terms of investing and banking, Gibraltar offers a stable and well-regulated
jurisdiction, with offshore trusts and 'exempt' companies (for the purposes
of tax minimisation) a particular speciality. The tax regime is favourable
for investors, although not so wonderful for residents, there are no exchange
controls, and with the exception of the ongoing disagreements with Spain,
the jurisdiction is politically stable. There were 26 banks in Gibraltar
in 1996, but by 2009 the number had dropped to 18. The banking sector
is well established in both the offshore and local market, with assets
in the vicinity of G£8.3 billion. The regulatory regime falls in
line with both the Basle and EU requirements. The Gibraltar Deposit Protection
Board operates a deposit protection scheme (did the name give it away?).
Residence and employment in Gibraltar are reasonably easy to obtain if
you are an EU national, as you will usually be issued with a six month
entry visa, followed by a five year renewable permit if suitable employment
has been found, or if a business has been set up.
Non-EU nationals are more limited in their options, but there have traditionally
still been several ways of obtaining residence and work. Aside from applying
for a job that no resident Gibraltarian is willing to do (nice!), there
were more appealing status options for the expatriate. These included:
- Category 2 individuals. Of recent years, Gibraltar has made a number
of concessions in order to persuade High Net Worth Individuals to make
Gibraltar their home, and for a one-off payment of GBP500, and the provision
of 2 letters of reference (one of which must be from a banker), a certificate
will be issued, limiting the individual's liability for taxation to
the first GBP50,000 of assessable income, with all further income being
tax free. (This usually results in a tax bill of around GBP28,750).
From 1 July 2007, the minimum tax payable was increased from GBP14,000
per annum to GBP18,000 per annum and the taxable income level was increased
from GBP50,000 to GBP60,000.
- Category 3 individuals. If an expatriate executive is working for
an Exempt or Qualifying company (the usual choices for a foreign investor),
then their employer can usually apply for a renewable (3 yearly) certificate
at a cost of GBP500, capping the tax payable at GBP10,000, whatever
their eventual income. Category 3 status was abolished for new entrants
in 2007. Existing Category 3 holders will be able to retain that status
until expiry of their current certificate or for two years until 30
June 2009, whichever is the longer. However, the amount of tax payable
rose with effect from 1 July 2007 from GBP10,000 to GBP15,000 per annum.
A new category called ‘High Executive Possessing Specialist Skills’
(HEPSS) was established for existing Category 3 holders who earn more
the GBP100,000 per annum, and new applicants who possess skills not
available in Gibraltar and, in the Government’s opinion, necessary
to promote and sustain economic activity of particular economic value
to Gibraltar, who will occupy a high executive or senior management
position, and who will earn more than GBP100,000 per annum of income
in Gibraltar.
- Category 4 individuals. Relocated Executives Possessing Special Skills
(or REPSS) can apply for a certificate valid for 3 years (and costing
GBP500) limiting their tax bill to GBP5,000 (on an income of GBP50,000
or less), or GBP10,000 otherwise. In order to be eligible for this permit,
however, they must be able to prove that they are providing a service
or skill not available in Gibraltar, and that their employment will
be of benefit to the economy of Gibraltar. The employer has to create
another job for a Gibraltarian alongside. Category 4 Status was abolished
for new entrants with effect from 1 July 2007. Existing holders may
retain the status until the end of the current certificate or 30 June
2009, whichever is the longer. However, minimum tax payable will increase
with effect from 1 July 2007 from GBP5,000 per annum to GBP7,500 per
annum.
In 2007, Gibraltar's Chief Minister Peter Caruana unveiled some amendments
to the jurisdiction's' high-net-worth individual (HNWI) scheme. For HNWIs
this scheme was to remain largely intact except that with effect from
1 July 2007 the minimum tax payable would be increased from GBP14,000
per annum to GBP18,000 per annum and the taxable income level increased
from GBP50,000 to GBP60,000.
Category 3 status was abolished for new entrants. Existing Category 3
holders were able to retain that status until expiry of their certificate
or for two years until 30 June 2009, whichever was the longer. However,
the amount of tax payable was to rise with effect from 1 July 2007 from
GBP10,000 to GBP15,000 per annum.
A new category called ‘High Executive Possessing Specialist Skills’
(HEPSS) was established for:
- Existing Category three holders who earn more the GBP100,000 per annum;
- New applicants who possess skills not available in Gibraltar and,
in the Government’s opinion, necessary to promote and sustain
economic activity of particular economic value to Gibraltar, who will
occupy a high executive or senior management position, and who will
earn more than GBP100,000 per annum of income in Gibraltar.
Tax would be payable only on the first GBP100,000 per annum of income
under the dual choice tax system. New applicants may not have been resident
in Gibraltar for any part of the period of three years immediately preceding
the application.
Category 4 Status was abolished for new entrants with effect from 1 July
2007. Existing holders retained the status until the end of the current
certificate or 30 June 2009, whichever was the longer. However, minimum
tax payable was to increase with effect from 1 July 2007 from GBP5,000
per annum to GBP7,500 per annum.
Since 2007, there have been two parallel systems of income taxation.
The first system is the existing Allowance Based System under current
tax rates, which were reduced in that year's budget. The top rate of tax
was reduced from 42% to 40%. The standard tax rate band (on which tax
is paid at 30%) was widened by GBP3,000 from the previous GBP4,000 to
GBP13,000 to GBP4,000 to GBP16,000.
The alternative system is a new Gross Income Based system, in which the
taxpayer will receive no allowances, but will pay tax on gross income
at the following rates: 20% on the first GBP25,000; 30% on the next GBP75,000;
40% above GBP100,000.
As a result, no taxpayer with income below GBP25,000 per annum will pay
more than 20% income tax; no taxpayer with income below GBP50,000 will
pay more than 25% income tax; no taxpayer with income below GBP100,000
will pay more than 27.5% income tax; and no taxpayer with income below
GBP125,000 per annum will pay more than 30% income tax.
Whether you are planning to spend your dotage on 'The Rock', or whether
you mean to retire at 40 and live the high life, the lifestyle offered
to you by any jurisdiction will be high on your list of concerns.
The Gibraltar lifestyle may be of most interest to UK expats, due to
the close relationship between the two countries, and the official language
is English, although Spanish, Italian, Portuguese and Russian are also
spoken. There is a great deal of cultural diversity on the peninsula,
and the majority of the country is Roman Catholic, although there are
also Protestant, Muslim, and Jewish communities. There are several English
language newspapers available, and the nightlife has a distinctly British
flavour (and can hence become a bit rowdy!) Water sports and wildlife
pursuits are available for the more active expat, and crime rates are
generally low.
A final word of warning - Gibraltar, in common with many other offshore
jurisdictions, offers tax breaks to non-residents, but not to residents,
so although Gibraltar may be a good base for your assets during your working
life, if it is where you plan to live on retirement, you need to consider
the impact of taxation on your income.
For a more detailed treatment of the tax and legal regimes in this and
40 other offshore jurisdictions, please visit the Lowtax
Jurisdictions Guide.
GUERNSEY
Language - English and French
Currency -
UK Pound
Status -
UK Crown Dependency
Population -65,500 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| One
rate of 20% |
Employee
pays 6.5% |
Until
March 25, 2009, Dwellings Profit Tax : 100% on profits from sale
of dwelling or land unless used for genuine residence purposes |
N/A
|
| STAMP
DUTY |
OTHER
TAXES |
TAX
RESIDENCE QUALIFICATION |
BASIS
OF RESIDENT TAXATION |
| N/A
|
N/A
|
Present
for more than 182 days, or possession of a dwelling place |
Solely
and principally resident : World-wide income |
| LEGAL
BASIS OF RESIDENCE |
COST
OF RESIDENCE DOCUMENT |
WORK
PERMIT REQUIRED? |
WORK
PERMIT AUTHORITY |
| RTW
Permit for limited period; long term residence based on individual
status |
N/A
|
Yes
: For non EU nationals |
Immigration and
Nationality Division of the Home Department |
Guernsey
Guernsey is a very well respected offshore financial sector,
and although the financial sector is similar in many ways to that of Jersey
(for example the consistently favourable tax regime, lack of exchange
controls, and strict regulatory controls), there are important differences,
for example in terms of particular areas of expertise.
Europe's largest captive insurance sector is located in Guernsey; 2009
GFSC statistics show that Guernsey plays host to a total of 678 international
insurance entities. This comprises 355 international insurers –
made up of 281 traditional captives, 63 Protected Cell Companies (PCCs),
5 Incorporated Cell Companies (ICCs) and 6 ICC cells. There are also 323
PCC cells, split between 250 conventional PCC cells and 73 PCC cells writing
life insurance. Additionally, in the areas of PCCs, there is rising interest
in special purpose vehicles (SPVs), although these are usually only arranged
by well capitalised companies.
The island is also well respected in terms of its advisory and financial
infrastructure, and expertise in trust formation and management (there
are more than 200 firms offering fiduciary trust services in Guernsey,
and over GBP50 billion in trust assets are held there). Investment funds
are flourishing alongside the Channel Islands Stock Exchange (based in
Guernsey).
Banking is also a major source of revenue on the island. As of September
2010, there were more than 40 licensed banking institutions in Guernsey
(all of which are subsidiaries or branches of the top foreign banks),
and although the number of institutions has remained approximately the
same since the rapid growth period in the 1980's, the deposit base has
continued to grow, with only a quarter of the amount held actually in
sterling, reflecting the increasing internationalisation of the island's
financial sector. Banks are regulated by the Financial Services Commission
(as in Jersey), and the capital adequacy rules surpass the Basle requirements.
The immigration and residence legislation is similar to that of Jersey,
and for the same reasons, namely limited space and resources, and a desire
to preserve the quality of life for existing residents. As a result, although
it is possible to obtain short term residence and employment (with a 'Right
to Work', or RTW permit), long term and permanent residence are very difficult
to obtain. There are no real concessions made to ordinary (i.e. not HNWI)
expatriates, or employees of resident exempt or qualifying companies -
the RTW permit grants permission to reside on the island for its duration,
and conversely, permission to reside automatically confers the right to
a RTW permit.
Tax residence in Guernsey is assumed if an individual is present there
for more than 182 days, or if they possess a dwelling place on the island.
A solely and principally resident individual will be liable for taxation
on world-wide income. A person not in possession of a dwelling place in
Guernsey is usually deemed to be resident, but not solely and principally
so. As such, they will usually only be taxed on Guernsey source income,
or income remitted to Guernsey.
Both English and French are spoken widely, and there are a couple of
English language newspapers available. The temperate climate (mild in
the winter, but cool in the summer) means that water sports, walking,
cycling, and golf are among the leisure options available, and Christianity
is the dominant religion, with Anglican, Baptist, and Congregational communities
in evidence.
As with Jersey, despite its manifest advantages as an offshore base for
your assets during your working life, unless you are exceptionally well
off, your chances of being allowed to retire to Guernsey are very slim.
For a more detailed treatment of the tax and legal regimes in this and
40 other offshore jurisdictions, please visit the Lowtax
Jurisdictions Guide.
IRELAND
Language -
Irish, but English in everyday use
Currency -
Euro
Status - Democratic Republic
Population - 4.2m |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| Progressive
rates to 41% plus a 2%, 4% or 6% levy |
Employee
pays between 8% and 10.75% depending on pay |
25%
exit tax on funds |
N/A
|
| STAMP
DUTY |
OTHER
TAXES |
TAX
RESIDENCE QUALIFICATION |
BASIS
OF RESIDENT TAXATION |
| Not
for property up to EUR125,000. The next EUR875,000 pays 7%; and
the excess over EUR1,000,000 pays 9% |
N/A
|
Present
for more than half of tax year, or 280 days over 2 years |
Resident
and domiciled: World-wide income |
| LEGAL
BASIS OF RESIDENCE |
COST
OF RESIDENCE DOCUMENT |
WORK
PERMIT REQUIRED? |
WORK
PERMIT AUTHORITY |
| Certificate
of Registration (Green Book) |
N/A |
Yes
: for non-EU nationals |
Department
of Enterprise, Trade, and Employment |
Ireland
In the investment and banking sector, Ireland has experienced
a great upsurge in the number and types of provider available, due in
great part to the establishment of the IFSC (International Financial Services
Centre), which encouraged banking and investment providers to physically
locate in the old docks area in Dublin. However the tax incentives concerned
were phased out in favour of a uniform 12.5% rate of corporation tax.
The jurisdiction is particularly well thought of in terms of expertise
in the following areas:
- Banking. There are hundreds of banks established in Ireland, all of
which are strictly licensed and regulated by the Central Bank.
- Establishment and management of investment funds, many of them linked
to life assurance - changes to the tax regime in 2001 increased the
attractiveness of many of these funds to Irish residents
- Management and holding of international financial activities
There are no exchange controls in Ireland, and the political situation
seems to be moving towards greater stability, although religious and political
tensions do still exist.
Nationals of European Union member states have free right of movement
in Ireland. Nationals of other states wishing to work in Ireland require
a work permit from the Department of Enterprise, Trade and Employment.
The Department is obliged to issue permits when the employee has a key
role, or is transferring from an international company which has or intends
to have a presence in Ireland. However, the rules have recently been relaxed
for certain clases of foreign national, including inter-corporate transferees,
the spouses of EU nationals, and non-EU nationals who have had a child
born in Ireland. In these cases letters from the employee's foreign employer,
and the prospective Irish employer are now sufficient to immigrate for
one year. However it is advised to check the current situation before
attempting to immigrate.
New economic migration and employment permit arrangements for workers
outside of the European Economic Area came into effect in Ireland from
February 1, 2007.
The four categories of permits that have been introduced include: the
Green Card Scheme; the Work Permit; the Intra Company Transfer Permit;
and Spousal and Dependant Permits. The Employment Permits Act passed by
the Oireachtas, together with the Employment Permits Act 2003, provide
the statutory basis for the new schemes.
The Green Card scheme, introduced for the first time in Ireland, is aimed
at occupations where the country has "strategically important high
level skills shortages," such as in the Information and Communications
Technology, Health Care, Construction, Engineering, Financial Services
and Research sectors. The scheme is available for an extensive list of
occupations with annual salaries of EUR60,000 (US$77,630) and above, and
for a specified list of occupations with salaries between EUR30,000 and
EUR60,000.
No labour market test is required for the Green Card applications, so
advertising with FAS/EURES and newspapers is not necessary. Green Cards
are issued for two years initially and normally lead to the granting of
permanent or long-term residence after that. Green Card holders are also
permitted to bring their spouses and families to join them immediately.
The Green Card Scheme replaces the previous Work Visa/Work Authorisation
scheme, which has been discontinued.
The new Work Permit is mainly for non-Green Card occupations in the EUR30,000
to EUR60,000 annual salary range. It is only granted in exceptional circumstances
for occupations with salaries below EUR30,000. In order to establish that
vacancies which are the subject of Work Permit applications cannot be
filled by Irish or other European nationals, as required by our EU 'Community
preference’ obligations, they are the subject of a "rigorous"
labour market needs test. This test includes both advertising with FAS
and the European Employment Services, or EURES, and in local and national
newspapers. Work permits are granted initially for a period of 2 years,
and then for a further period of up to 3 years.
The concept of domicile comes into play in the calculation of tax liability
in Ireland, but as this is normally (although not always) the result of
having an Irish-domiciled father, most foreign nationals are not considered
to be domiciled in Ireland, even if they are resident there. Tax residence
is assumed if an individual is present in the country for more than half
of the tax year, or over 280 days in two years. The liabilities are as
follows:
- Domiciled and resident: Liable for tax on world-wide income
- Resident but not domiciled: Liable on foreign income only if remitted
to Ireland.
Although Irish is the official language, English is spoken widely on
both a business and day-to-day level, and there are several English language
newspapers available. The majority of the population (95%) is Roman Catholic,
with the Protestant community making up the remainder, and outdoor pursuits
such as horse riding, cycling, fishing and golf are popular, despite the
slightly damp climate.
There are a few options available for the expat resident in Ireland as
regards retirement investment, but it is worth bearing in mind that for
the expat living in Ireland, who will normally not be domiciled, offshore
investment will not be taxable in Ireland provided the proceeds are not
remitted there.
For a more detailed treatment of the tax and legal regimes in this and
40 other offshore jurisdictions, please visit the Lowtax
Jurisdictions Guide.
JERSEY
Language - English and French
Currency -
UK Pound
Status -
UK Crown Dependency
Population - 92,000 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| One
rate of 20% |
Employee
pays 6.5%, self-employed pay 12.5% |
N/A
|
Stamp
duty is imposed on the transfer of real estate at variable rates |
| STAMP
DUTY |
OTHER
TAXES |
TAX
RESIDENCE QUALIFICATION |
BASIS
OF RESIDENT TAXATION |
| N/A
|
N/A
|
Present
for more than 6 months in any tax year, 3 months per year over 4
year period, or Jersey abode visited at any time |
Resident
and ordinarily resident : World-wide income |
| LEGAL
BASIS OF RESIDENCE |
COST
OF RESIDENCE DOCUMENT |
WORK
PERMIT REQUIRED? |
WORK
PERMIT AUTHORITY |
| Dependent
on individual residence status rather than employment |
N/A |
Yes
: For non EU nationals |
Immigration
Office |
Jersey
Jersey has an international reputation as one of the world's major important
financial centres, and as such is very attractive to foreign workers and
investors. The jurisdiction is particularly well respected in the following
areas:
- Banking. Banking deposits in Jersey fell by 6% during the second quarter
of 2010, to GBP166.9bn.
- Trust formation and management. Total trust assets held in Jersey
exceed GBP100 billion.
Financial and advisory services are generally of a very high standard.
The financial sector is regulated by the Financial Services Commission,
and in terms of banking, the capital adequacy rules are considerably stiffer
than the Basle requirements.
Jersey, in common with Guernsey, is in an unusual position in terms of
residence, as there is limited space and resources, and the existing residents
are keen to maintain the quality of life. Immigration policy reflects
this situation, and permission for long-term residence is almost never
granted.
In establishing tax residence, there are several categories: residence,
ordinary residence (implying a more continuous presence on the island)
and non-residence. An individual who is resident and ordinarily resident
is liable for tax on their world-wide income, whereas a resident (but
not ordinarily resident) person will only be taxed on income arising in
Jersey, or foreign income remitted there. There are no real concessions
made, or incentives offered for expatriate executives in terms of residence
or taxation; in Jersey, there are no broad provisions made - it is your
individual situation which is important.
English and French are both official languages in Jersey, (although the
former is more often used for business purposes), and there are two main
English language newspapers in circulation on the island. The climate
is mild and sunny, with golf proving equally popular with expatriates
and residents alike, and the population is predominantly Christian.
The bottom line if you are thinking of retiring to Jersey is
not
unless you are extremely well off! As previously mentioned, long term
residence in Jersey is almost an impossibility, and the only time that
exceptions are made is in the case of HNWI purchasing substantial (preferably
luxury) property, and who will obviously contribute a great deal to the
island's economy in terms of taxes and investment.
For a more detailed treatment of the tax and legal regimes in this and
40 other offshore jurisdictions, please visit the Lowtax
Jurisdictions Guide.
MALTA
Language - Maltese and English
Currency - Euro
Status - Parliamentary Democracy
Population - 406,700 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
For individuals, to EUR8,500: Nil,
after that between 15-35%
|
Employee
pays 10% of basic weekly wage |
Capital
gains are included in taxable income |
There
is a tax of 5% on the transfer of real estate |
| STAMP
DUTY |
OTHER
TAXES |
TAX
RESIDENCE QUALIFICATION |
BASIS
OF RESIDENT TAXATION |
| Share
transfers: 2%, Share issues: 0.4% |
N/A
|
Present
for more than 6 months |
Domiciled
and resident: World-wide income |
| LEGAL
BASIS OF RESIDENCE |
COST
OF RESIDENCE DOCUMENT |
WORK
PERMIT REQUIRED? |
WORK
PERMIT AUTHORITY |
| Residence
Permit |
N/A
|
Yes
: Stringent requirements, because of high unemployment |
Principal
Immigration Officer |
Malta
Maltese banking and investment has traditionally been quite a small scale
and local affair, but with the introduction of the Maltese stock exchange,
and its continuing success in attracting mutual fund listings, this may
all be set to change. Growth areas in Malta include banking, investment
fund management, trust management, and investment holding, and there are
several hundred foreign companies established on the island.
There are also a number of local banks (but very few foreign banks, as
foreign banking activity was very strictly controlled until recently),
and these are regulated by the Maltese Financial Services Authority. Although
legislation governing the financial sector was relatively late in arriving,
the professional and business infrastructure is good, and as a result,
reasonably well regulated.
Malta levies moderately high internal taxes, but offers low tax incentives
to individual foreign investors and companies alike.
The island has experienced some problems since it became independent
from the UK, and when the British military withdrew in 1979, the economy
slumped, and the political conditions were not good for business investment.
However, the situation has improved vastly, and the financial sector is
developing well.
In order to obtain a residence permit, a foreign national must be able
to demonstrate sufficient income or capital, and must agree to buy or
rent local property on the island.
Work permits, however, are a little harder to get hold of, and due to
the historically high level of unemployment on the island, the criteria
are quite strict. The Principal Immigration Officer must be applied to,
and a permit is usually only issued if there is no suitably qualified
Maltese resident available to fill the position, and if the prospective
employer agrees to put in place training and understudying programmes.
Tax residence is assumed if an individual is present for more than six
months in any tax year, and Malta is one of the few jurisdictions in which
the concept of domicile comes into play when calculating tax liabilities,
which are as follows:
- Domiciled and resident: Liable on world-wide income
- Resident (but not ordinarily resident) and not domiciled: Taxable
only on Maltese income, and foreign income remitted to there.
The principal languages spoken in Malta are Maltese and English, although
some Italian is spoken, and there are a number of English language newspapers
available. The warm weather throughout the year means that pursuits such
as walking, cycling and golf are popular, and there is a strong and active
Roman Catholic community in place on the island.
The attractive standard of living, and number of tax breaks available
for foreign national retirees (i.e. lack of property, estate, municipal,
and local taxes, and absence of income and capital gains taxes on income
arising outside Malta if not domiciled there) mean that overall, Malta
is a very attractive destination as a retirement haven.
For a more detailed treatment of the tax and legal regimes in this and
40 other offshore jurisdictions, please visit the Lowtax
Jurisdictions Guide.
PANAMA
Language - Spanish, but English widely spoken
Currency -
US Dollar
Status - Constitutional republic
Population 3.4m |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| Progressive
to 27% |
Employee
pays 8% plus 1.25% educational tax |
Levied
on real estate gains at 30% but the basis is complex |
Tax
levied annually on sliding scale up to 1% |
| STAMP
DUTY |
OTHER
TAXES |
TAX
RESIDENCE QUALIFICATION |
BASIS
OF RESIDENT TAXATION |
| On
official public documents; seller pays 2% on real estate transfers
|
N/A
|
Present
for 180 days in tax year |
Territorial
Basis |
| LEGAL
BASIS OF RESIDENCE |
COST
OF RESIDENCE DOCUMENT |
WORK
PERMIT REQUIRED? |
WORK
PERMIT AUTHORITY |
| Different
types of visa (See summary) |
N/A
|
Yes
: for anyone other than Panamanian citizens |
Ministry
of Labour and Social Welfare |
Panama
Panama is the premier jurisdiction for offshore banking
and shipping in Central and Southern America. Although it gained something
of an unsavoury reputation in the 1980's, the government is attempting
to move away from this image, and the incentives offered to foreign and
domestic investors and an efficient banking system seem to be having the
desired effect; the volume of trade and number of individual clients using
Panama as a base for their offshore activity has increased dramatically
over the past few years.
Panama operates a territorial tax system, meaning that only income arising
in Panama or from there is liable to taxation.
However, a fiscal reform package introduced in 2005 and which took effect
from 2006 in most respects has changed the rules in some ways:
According to the newly introduced Paragraph 1-A of article 694 of the
Fiscal Code, income derived from personal services such as wages, salaries
and other personal remunerations will be treated as originating from a
source located within Panamanian territory – even though such personal
services may be physically and actually rendered both within and outside
Panamanian territory – if the individual taxpayer resides in the
Republic of Panama for at least 70% of the calendar days of any given
year.
There are no exchange controls.
Banking legislation is liberal, and there are tight secrecy provisions.
There are over 120,000 companies established in Panama, and around 80
licensed banks (2008), most of which specialise in South and Central American
business. The large banking industry is regulated by the National Banking
Commission, which fulfils some of the responsibilities of a central bank
(as there isn't one), and grants banking licenses. The commission is very
selective in granting licenses, and overall, branches of well-established
and respected banks are preferred.
There are several different types of visa available for those wishing
to work and live in Panama, including one specifically designed to ease
the passage of the wealthy expatriate retiree into Panamanian life. Briefly,
these are:
- Tourist Visa. A short term (up to 3 months) visa, which is easily
obtainable
- Temporary Visitor Visa. Easily obtainable
- Special Temporary Visitor Visa. Easily obtainable
- Tourist Pensioner Visa. This is given to retirees who can demonstrate
a monthly income of $750 or more from interest on time deposits in Panamanian
banks.
- Immigrant Visa. Given to long-term working residents
- Investor's Visa. Given to those who invest their own capital in local
business activity in areas such as the commercial, financial, agricultural,
industrial, or reafforestation sectors.
In order to work in Panama, however, a work permit (usually valid for
one year) will need to be obtained from the Ministry of Labour and Social
Welfare. Bear in mind that there are restrictions placed on the number
of non-Panamanian citizens that can be employed by any company, even foreign
companies (although there the quota is higher).
Expats planning to retire to Panama will almost certainly find something
to their taste, with the tropical climate ensuring that pastimes such
as water sports, fishing and golf are perennially popular. The majority
of the population is Roman Catholic, and the entertainment options are
many and varied, with night clubs, casinos and theatres available in the
major cities.
As previously mentioned, Panama actively encourages wealthy pensioners
to retire there, and Pensionado residence (available to expats that can
demonstrate a certain level of verifiable monthly income for themselves
and their dependents, and a clean bill of health) could be an attractive
option. As a Pensionado resident you would be eligible for many 'perks',
including discounts on a range of services and utilities, and tax breaks
on the importing of household goods, and automobile purchase.
For a more detailed treatment of the tax and legal regimes in this and
40 other offshore jurisdictions, please visit the Lowtax
Jurisdictions Guide.
SWITZERLAND
Language - French, German, Italian and Romansch
Currency -
Swiss Franc
Status -
Federal Republic
Population - 7,600,000 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| Levied
at federal, cantonal and communal levels; doesn't usually exceed
40% |
old
age and widows insurance, disability insurance, and income loss
insurance of 5.05%, unemployment of 1%, and occupational pension
contribution of approx. 7.5%; payments shares equally between employee
and employer |
Capital
gains tax on real estate transactions averages 18% |
N/A
|
| STAMP
DUTY |
OTHER
TAXES |
TAX
RESIDENCE QUALIFICATION |
BASIS
OF RESIDENT TAXATION |
| 1%
on issue of shares where value is over SFr250,000 |
Inheritance
Tax and Wealth Tax |
Present
for more than 180 days (or 90 if in same abode constantly) |
See
summary |
| LEGAL
BASIS OF RESIDENCE |
COST
OF RESIDENCE DOCUMENT |
WORK
PERMIT REQUIRED? |
WORK
PERMIT AUTHORITY |
| Residence
Permit |
Varies
accrording to type of permit |
Yes
: tied in with residence permit |
N/A
|
Switzerland
Switzerland has established a world-wide reputation as one of the world's
premier financial centres, and is famed for being a neutral, secure low
tax jurisdiction, with stringent banking secrecy legislation. It could
be argued that the necessity of preserving this reputation prevents participation
in some of the more risky (but potentially more profitable) growth areas
of investment. However, if you are looking for solid gains, security,
and a guaranteed reputation, then Switzerland is probably the jurisdiction
for you. The political stability of this jurisdiction is one of its main
'selling points'.
Switzerland has always been best-known for its banking sector, with over
500 major banking institutions estimated to hold approximately 35% of
the world's private wealth. Switzerland's decision to remain outside the
EU and its insistence on retaining banking secrecy have reinforced its
attractions as a safe home for wealth. Switzerland does however impose
withholding taxes on many types of payment leaving the country, so it's
not necessarily suitable as a base for wealth which is to be used to provide
ongoing income in another country.
The Swiss are generally moderately taxed, with the process taking place
at federal, cantonal, and communal levels, and there are no exchange controls.
The processes for obtaining residence, employment, and permission to
purchase real estate are intertwined, with a number of different permits
offering varying degrees of freedom to the bearer:
- 120 day permit. This permit allows a specialist or managerial worker
to reside in Switzerland for up to 120 days, filling a specified position.
This is the only permit not subject to a quota system.
- Class A permit. This is granted to 'blue collar workers'.
- Class B permit. This permit is usually issued to professionals, those
who want to start a business in Switzerland, and those wealthy enough
to live off their own resources whilst resident. This is the most commonly
issued permit, and is usually valid for a year at a time, entitling
the bearer to bring their spouse and children to live with them. However,
the expatriate worker must be immigrating in order to fill a specific
position, and must not be depriving a Swiss national of employment by
taking the job. The residence permit for EC/EFTA nationals is valid
for five years if they are in possession of an employment contract of
at least twelve months’ duration or of unlimited duration. Additional
temporary regulations apply for EU-8 (the countries which aceded to
the EU in 2005) and EU-2 (Bulgaria and Romania) nationals. The residence
permit will be renewed for another five years without any further procedures
if the foreign national satisfies the relevant requirements. On the
occasion of its first renewal, however, the permit can be limited to
one year if the holder has been involuntarily unemployed for more than
twelve consecutive months.
- Class C permit. This is intended to provide longer-term residency,
and provides the permit holder with the same rights as a Swiss citizen
(among them, the right to purchase local real estate). To be eligible
for a Class C permit, the expat must have been in possession of a Class
B permit for between 5-10 years, with the length varying according to
country of origin.
- Fiscal Deal Permit. This type of permit is suitable for the retired
HNWI with a verifiable net worth of (at the time of writing) over 2
million Swiss Francs, who is willing to spend at least 180 days per
year physically present in Switzerland.
In September, 2005, a 56% majority of Swiss voters approved proposals
to open the country's borders to workers from new EU member states. The
vote in favour of the extension of the bilateral agreement on freedom
of movement to the ten new members was welcomed by both the Swiss authorities
and the European Commission, as there had been some uncertainty as to
the public mood on the matter.
The free movement of persons between Switzerland and the ten new EU member
states will be introduced by separate transitional provisions regulated
in an Additional Protocol to the existing Agreement on the Free Movement
of Persons. Regulations applicable to third-country nationals will continue
to apply until the Additional Protocol comes into force. On 31 May 2007,
quotas for EU citizens wishing to work in Switzerland were suspended.
Freedom of movement will be fully introduced between Switzerland and the
EU as of June 2014.
Residence for tax purposes is assumed if an individual is in Swiss employment,
carries on business there, or is present in the country for more than
180 days in any one tax year. As previously stated, there is no centralised
tax regime as such, due to Switzerland's federalised nature, and with
the exception of 'Fiscal Deal' residents, no distinction is made between
residents and non-residents in terms of income tax, capital gains tax,
stamp duty, etc.
Languages commonly spoken in Switzerland include German, French, Italian
and English. Although the most popular newspapers are published in French
and German, there are a multitude of English-language European and international
newspapers available. The climatic variations caused by the Alps mean
that popular leisure pursuits include hiking, cycling, and both winter
and water sports. The religious community in Switzerland is fairly evenly
split, with 49% of the population Roman Catholic, and 48% Protestant.
Switzerland is one of the few jurisdictions with special provisions for
foreign nationals hoping to retire there, and for those with sufficient
assets, the aforementioned 'Fiscal Deal' is an ideal retirement option,
providing substantial tax advantages, as individuals are not taxed on
their actual yearly income or assets, but on a nominal amount.
For a more detailed treatment of the tax and legal regimes in this and
40 other offshore jurisdictions, please visit the Lowtax
Jurisdictions Guide.
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