BAHAMAS
Language
- English
Currency - Bahamian Dollar
Status - Independent Commonwealth
State
Population
- 305,655 |
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
2% to 8% |
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
|
Bahamas
Investment Authority |
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
- 46,600 |
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% 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 |
Chief
Immigration Officer |
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 USD1.7 trillion. 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.
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
- 788,457 |
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-resident) |
From
2.5-4% on property over EUR160,000 but based on 1980 values |
| 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 |
Immigration
Department and Central Bank |
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 approx. EUR3,000 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
- 27,967 |
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-GŁ500 (Indefinite), Cat 3 or 4-GŁ500 (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.
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
-65,573 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| One
rate of 20% |
Employee
pays 6% |
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 |
States
Defence Committee of the Aliens Office |
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; at 31st October 2007, there were in
total 638 international insurance companies registered
in Guernsey, comprising 303 captives, 71 PCCs
and 262 PCC cells. Total assets in 2006 stood
at GBP18.8 billion. 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 June 2005, there were more than fifty 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 third
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 35 other offshore jurisdictions,
please visit the Lowtax
Jurisdictions Guide.
IRELAND
Language
-
Irish, but English in everyday use
Currency -
Euro
Status - Democratic Republic
Population
- 4,109,086 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| Progressive
rates to 41% plus a 2%, 4% or 6% levy |
Employee
pays between 6% and 8% 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 EUR150,000. After that,
ranges from 3% to 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.
It
is relatively easy for EU nationals to enter the
country, and on arrival, no residence or work
permit is necessary. Australian, Canadian and
US citizens do not need to apply for a residence
permit, but all other groups will need a work
and residence permit for the duration of their
visit.
Although
Irish law does not allow for permanent residence
as such, any individual who has been granted a
visa, and wants to stay in the country for longer
than three months (for the purposes of starting
a business, seeking employment, or marrying an
EU or Irish resident), can apply for a Certificate
of Registration (or Green Book) from the local
constabulary in their area of residence. The registration,
if successful, will act as permission to reside,
and will need to be renewed at regular intervals.
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
- 91,321 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| One
rate of 20% |
Employee
pays 6%, 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 |
States
Defence Committee of the Aliens 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. Total deposits held with Jersey banks at the end of December
2008 increased in sterling terms by GBP20.8bn from the end of September
2008 level of GBP136.3bn to reach a new highest figure of GBP157.1bn,
representing a 15.3% increase over the quarter and 31.9% over the year.
Total assets and liabilities increased by GBP27bn over the quarter representing
a 17.8% increase to reach the highest level yet at GBP179.2bn. This
represents a 35.9% increase over the year.
- 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
- 401,880 |
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
Centre. 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
3,242,173 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| Progressive
to 27% |
Employee
pays 7.25% 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
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
- 7,554,661 |
INCOME
TAX |
SOCIAL
TAXES |
CAPITAL
GAINS TAX |
PROPERTY
TAX |
| Levied
at federal, cantonal and communal levels;
doesn't usually exceed 40% |
Usually
about 13.1% of employee's salary; paid by
them and the employer in equal amounts |
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.
-
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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