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BERMUDA

Language - English

Currency - Bermuda Dollar (although USD widely accepted)

Status -
Self-governing British Dependency

Population - 66,163

INCOME TAX
SOCIAL TAXES
CAPITAL GAINS TAX
PROPERTY TAX
N/A
Employee pays $21.34 per week, increased by 4.75% in 2005. Self-employed pay twice this
N/A
22% payable by foreigners on purchase of real estate
STAMP DUTY
OTHER TAXES
TAX RESIDENCE QUALIFICATION
BASIS OF RESIDENT TAXATION
Duty on Bermudan assets on grant of probate: 5% on value between $20,000 and $100,000 and 10% thereafter
Payroll taxes: Employer pays up to 13.5%
Possession of work permit
No direct taxes
LEGAL BASIS OF RESIDENCE
COST OF RESIDENCE DOCUMENT
WORK PERMIT REQUIRED?
WORK PERMIT AUTHORITY
Work permit allows residence while valid
N/A
Yes
Minister of Labour and Home Affairs


Bermuda

Early on in Bermuda's development as an offshore financial centre, the decision was made to exclude foreign banks, but this does not seem to have harmed the jurisdiction's reputation as an international business location. Classical banking services in Bermuda were therefore provided primarily by the three established Bermudian banks, until the biggest of them, Bank of Bermuda, was taken over by HSBC in March, 2004, but these banks have adequate international correspondent networks with some overseas branches, and are equipped to provide the range of financial services necessary to conduct business offshore.

There are also a number of foreign firms now authorised to provide financial services (with the exception of deposit taking) internationally, although they cannot as yet participate on a local level unless 60% local ownership can be established. The banking sector is regulated by the Bermuda Monetary Authority, and is generally regarded as strictly regulated.

The jurisdiction is also well regarded in the following areas:

  • Investment funds
  • Trusts and trust management
  • Insurance, including captive insurance

Exchange controls do not apply to non-residents or offshore entities, but do affect Bermudian citizens and local companies. There are no direct taxes levied, but payroll taxes, and annual fees by businesses are payable.

Obtaining residence and employment in Bermuda can be somewhat problematic (although it is, theoretically at least, possible), and affirmative labour legislation is being introduced which could affect the ability of local employers to take on expatriates. In order to preserve the limited resources of the islands, and maintain the standard of living of existing residents, Bermuda has, in effect, closed the door to long term residence applications, so while you may be allowed to reside there temporarily for work purposes, and it may be an ideal location for your assets while you are young and healthy, you may as well abandon those dreams of sunning yourself on a Bermuda beach after retirement!

In order to obtain a work permit, the prospective employer must apply to the Minister of Labour and Home Affairs on your behalf, having first proven that there was no suitably qualified Bermudian available to fill the position, and that no citizen of Bermuda will be disadvantaged by you taking the job. Work permits are usually issued for a year at a time (with the exception of work permits for senior executives which can be issued for longer periods), and the cost is met by the prospective employer.

Foreigners are more or less unable to buy land or property, other than houses with an Annual Rental Value (ARV) in excess of $43,800. equivalent to a sale price of say $500,000. A fee of 22% of the value of the property is payable on purchase.

The official business language of the jurisdiction is English, and there are several English language newspapers available. There are a variety of leisure pursuits and pastimes, including golf, water sports and tennis, and the climate is mild and humid. The majority of the population are Christian.

As previously stated, long term residence is exceptionally difficult to obtain, so unless you are very wealthy, retiring to Bermuda is probably not a viable alternative.

For a more detailed treatment of the tax and legal regimes in this and 40 other offshore jurisdictions, please visit the Lowtax Jurisdictions Guide.



DUBAI

Language - Arabic, but English widely spoken

Currency -
UAE Dirham

Status -
Member of the United Arab Emirates

Population - In the region of 1.4 million

INCOME TAX
SOCIAL TAXES
CAPITAL GAINS TAX
PROPERTY TAX
N/A
N/A
N/A
5% residential tax on rental value (10% for businesses)
STAMP DUTY
OTHER TAXES
TAX RESIDENCE QUALIFICATION
BASIS OF RESIDENT TAXATION
N/A
N/A
N/A
No taxes other than import tax, residential tax, and tax on hotel services
LEGAL BASIS OF RESIDENCE
COST OF RESIDENCE DOCUMENT
WORK PERMIT REQUIRED?
WORK PERMIT AUTHORITY
Residence Visa stamp in passport
N/A
Yes
Ministry of the Interior (Naturalisation and Immigration Department)


Dubai


There is a fairly clear distinction drawn between onshore financial services and offshore in Dubai, and the vast majority of offshore activity takes place in the Jebel Ali Free Zone, Dubai Internet City, and the more recently established Dubai International Financial Centre (DIFC). These zones have been created since 1985 for the purposes of facilitating investment, and all activity which takes place there is effectively seen legally as taking place outside the United Arab Emirates.

The jurisdiction has a highly developed banking industry, and with government initiatives to encourage e-commerce well underway, the various institutions are rushing to deliver more and more technologically advanced solutions. The banking sector is regulated by the Central Bank, and there are approximately 47 commercial banks operating (with a total of around 350 branches) of which 28 are foreign banks (with a combined total of more than 200 branches).

The Jebel Ali Free Zone and its fellows are advantageous areas in which to establish and administer an offshore company.

Taxation in Dubai is generally low (with the exception of the oil industry and domestic banking, where the rates are slightly higher), and there are no income or capital taxes, low import duties, and no withholding taxes. There are also no foreign exchange controls.

The Dubai Naturalization & Residency Department (DNRD) issues different types of visas which are listed below.

1) 96 hour visa:

  • Issued upon arrival at the airport
  • Airline sponsored only
  • Applicants should have onward booking
  • Should have a minimum of 8 hour transit break

2) Visit visa:
2.1 In case of Personal sponsorship:

  • Fees: Dhs 100
  • Entry permit application form with completed typed data
  • Original Marriage certificate and copy of it, in case of wife sponsorship
  • Salary Certificate; The monthly salary should not be less than Dhs. 4000 in case of wife sponsorship, and Dhs. 6000 in case of first relatives sponsorship.
  • Copy of the Sponsor passport
  • Copy of the Sponsored passport.

2.2 In case of Establishments sponsorship:

  • Fees: Dhs 100
  • Entry permit application form with completed typed data
  • Establishment card and copy thereof
  • Copy of the Sponsored passport.

2.3 Renewal:

  • Fees: Dhs 100
  • Original Entry Permit.

2.4 Extension:

  • Fees: Dhs. 500
  • Original Entry permit
  • Extension application form
  • Original sponsored passport.

3 - Transit visa

  • Fees: Dhs. 120
  • Establishment card
  • Entry Permit Application form
  • Copy of Sponsored passport.

4 - Tourist visa

  • Fees: Dhs. 100
  • Establishment card
  • Statement of tourists data

A Multiple Visit Visa can be granted after a normal visa has been issued and used, and is an option for business visitors who are frequent visitors to the UAE and who have a relationship with a reputable company in the UAE. Valid for six months from date of issue, each visit must not exceed 30 days in total. This visa costs Dh1000. The visitor must enter the UAE on a visit visa and obtain the multiple entry visa while in the country.

A Residence Visa stamped on a passport proves the legal residence of an expatriate in the country. This visa is given to workers who have obtained work permits or for relatives living with them permanently, and additional documentation is required.

Although Arabic is the official language in Dubai, English is spoken almost as widely, and there are three English language newspapers currently published there. The majority of the population is Muslim, with Sunni and Shiite accounting for 84% and 16% of people respectively. The climate is hot - the coolest part of the year is between October and May, and water sports and golf are the favoured pursuits of both locals and expatriates.

There are no real provisions for residence in Dubai on anything other than a relatively short term basis, and then only for the purposes of employment, so while Dubai may have advantages as on offshore base for assets, it may be difficult to obtain permission to retire 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.



HONG KONG

Language - English and Chinese

Currency -
Hong Kong Dollar

Status -
SAR of China

Population - 6,980,412

INCOME TAX
SOCIAL TAXES
CAPITAL GAINS TAX
PROPERTY TAX
Progressive from 2% to 17% after allowances, or a flat 15%
Those earning more than HK$4000 per month must pay 5% of salary up to maximum of HK$20,000 per month
N/A
15% of assessed annual rental income, plus annual rates tax of 4.5% of annual value of premises
STAMP DUTY
OTHER TAXES
TAX RESIDENCE QUALIFICATION
BASIS OF RESIDENT TAXATION
Sliding scale : To maximum rate of 3.75% on property over US$800,000
Estate Duty : Levied at progressive rate
N/A
Territorial Basis
LEGAL BASIS OF RESIDENCE
COST OF RESIDENCE DOCUMENT
WORK PERMIT REQUIRED?
WORK PERMIT AUTHORITY
Employment Visa (Different types-see summary)
N/A
Employment Visa required
HKSAR Immigration Department (Director of Immigration)

HONG KONG

In terms of both range and quality of financial and business services provided, Hong Kong is one of the world's leading jurisdictions. It is not an 'offshore' location as such, but the non-discriminatory low tax regime is run according to territorial principles, which means that only Hong Kong source income is liable for taxation, and there are a number of other incentives which have successfully attracted a great amount of foreign investment.

The jurisdiction is the world's third largest financial centre, and the financial and advisory infrastructure is of a very high standard generally. Hong Kong is a particularly advantageous location for the following sectors:

  • Banking. Hong Kong has the one of the largest colonies of international banks in the world, with more than 70 of the top 100 banking establishments having a presence there. In December, 2008, there were 142 licensed banks, 29 restricted licence banks and 29 deposit-taking companies in business. In addition, there are 79 local representative offices of overseas banks in Hong Kong.
  • Investment fund establishment and management. The jurisdiction is widely recognised as the leading fund management centre in Asia.
  • Investment and holding companies. These are a particularly attractive proposition in Hong Kong due to the benign tax regime and investment incentives offered.

There is no capital gains tax, withholding tax, sales tax, VAT, or annual wealth tax, and no one, resident or otherwise, pays tax on investment income or capital gains. There are no exchange controls, and the financial sector, which is regulated under the Banking Ordinance, is secure and well managed. A note of caution, however - Hong Kong is a relatively expensive jurisdiction in which to establish an offshore structure, so be warned that charges for services may be more than you would pay elsewhere.

There are several types of visa which will allow you entry to Hong Kong, and some are easier to obtain than others. Briefly, the categories of permit are:

  • Employment Visas. In order to obtain entry for the purposes of working in Hong Kong, you must first have an employer willing to take you on if your application is successful. You must also be providing a skill which is not available locally, and which is of benefit to the Hong Kong economy. This type of visa will generally be needed by :
  1. Inter-company transferees who are being relocated to work in the Hong Kong branch of their parent company. These are generally quite readily issued.
  2. Locally recruited expatriates, who have been offered a position whilst staying in Hong Kong. This type of visa is quite difficult to obtain, as the immigration department needs proof that there is no-one resident in the SAR already that could adequately fill the position
  3. Specially recruited expatriates who have been headhunted from abroad to do a specific job in Hong Kong. Again, these visas are sometimes difficult to obtain due to the need to convince the SAR that no one locally could fill the position.
  • Dependant Visas (for spouses and children of expats).
  • Investment-based Employment Visas. Once easy to obtain, the criteria which must be fulfilled in order to be eligible for this type of visa have become much more rigorous of recent times. It must be proved that the business is well capitalised, and can set up a local office and employ resident staff almost immediately. The enterprise must have the support of a well-established local or international business, and must demonstrate that it will be of benefit to the local economy.

In October, 2007, Hong Kong leader Donald Tsang announced new plans designed to ensure that Hong Kong's position as a leading global finance hub is consolidated and strengthened. He observed that China's rapid development and the opening up of its financial sector have presented unprecedented opportunities for Hong Kong's financial-services sector.

Tsang added that with these large-scale development projects, Hong Kong will need to expand its pool of skilled workers, and will "require talented people from everywhere". Consequently, to help attract more qualified people, the Quality Migrant Admission Scheme's requirements will be relaxed and widely promoted.

Although residence for taxation purposes is not really an issue, residents will have to pay salaries tax, social insurance, stamp duty, gifts tax, and property tax. However, compared to most onshore jurisdictions, the rates of taxation are low. Hong Kong does not offer any residential concessions based on property ownership due to overcrowding.

The majority of the population is Buddhist or Taoist, although the Christian community accounts for approximately 10% of the people. The principal languages are Chinese (usually Cantonese) and English, with the majority of official documents printed in both. There are several English language daily newspapers. The cost of living is reasonably high, with accommodation being the main expense, and the tropical climate means that leisure pursuits such as horse racing, golf, water sports, and contact sports are popular.

In terms of retirement, if you can gain admission and permission to reside (sometimes no mean feat!), and can cope with the relatively high cost of living, then Hong Kong is ideal, as income from retirement schemes is not taxed (even for residents), so it is a suitable jurisdiction in which to base a retirement fund, whether you plan to live there or not.

For a more detailed treatment of the tax and legal regimes in this and 40 other offshore jurisdictions, please visit the Lowtax Jurisdictions Guide.



ISLE OF MAN

Language - English

Currency -
UK Pound

Status -
UK Crown Dependency

Population - 75,831

INCOME TAX
SOCIAL TAXES
CAPITAL GAINS TAX
PROPERTY TAX
10% on first GBP10,500, and 18% on the balance
Employee pays 6.3%, Self-employed pay 11.6%
N/A
N/A
STAMP DUTY
OTHER TAXES
TAX RESIDENCE QUALIFICATION
BASIS OF RESIDENT TAXATION
N/A
N/A
Present for 6 months in tax year, or 3 months each year for 4 consecutive years
World-wide income
LEGAL BASIS OF RESIDENCE
COST OF RESIDENCE DOCUMENT
WORK PERMIT REQUIRED?
WORK PERMIT AUTHORITY
Legislation similar to UK
N/A
Yes
DTI (Employment Division)


Isle Of Man

The Isle of Man is respected as a developing and well-regulated International Offshore Financial Centre.

There are no capital or exchange controls, and the jurisdiction has a particularly good reputation in the following areas:

  • Banking. There are approximately 54 banks established in the Isle of Man at present, regulated by the Financial Supervision Commission, including branches and subsidiaries of the main UK clearing banks. The majority of these are engaged in providing private banking services to UK expats and foreign nationals, and as such the range of services available is extensive, including not just deposit taking, but also formation and management of trusts, companies, and their underlying assets.
  • Investment Fund establishment and administration.
  • Captive insurance.
  • Trust formation and management.

The Isle of Man is extremely stable politically; the Tynwald or Manx parliament was established by the Vikings! The taxation regime is moderate, with taxes of between 10 and 18% on resident individuals and on the Manx sourced income of non-residents.

The immigration procedure for the Isle of Man is very similar to that of the UK, and an Irish or UK resident will not need to contact the immigration department before arrival. Due to the recent expansion of the island's offshore sector, skilled expatriates are being encouraged to relocate there, and to buy property. The Isle of Man has a relatively low population density, and plenty of development land, so for the moment at least, it is better placed than smaller offshore centres (for example Jersey and Guernsey) in terms of population and economic growth.

However, better placed or not, there has been some discussion in parliament of the need to impose some kind of immigration controls on non-Manx individuals, in order to avoid disadvantaging the indigenous population in terms of employment and rising property prices.

Tax residence is assumed when an individual is present for more than six months in any tax year, or for an average of three months per year over four or more years. However, there is a concession for property owners which allows them to be resident for up to four months in two consecutive years without becoming liable for Manx income tax.

The original language of the Isle of Man is Manx Gaelic, but this has been marginalised now by English, which is most commonly used in business and day to day transactions. There are several English language newspapers, and the temperate climate means that outdoor pursuits such as motor racing, sailing, golf, and walking are popular with expats and locals alike. The island is predominantly Christian.

In terms of retiring to this jurisdiction, despite the many advantages it offers in terms of investing, banking, and professional financial services provided, it is worth remembering that although there are tax breaks available for non-resident individuals, local taxes will apply to your world-wide income as a resident.

For a more detailed treatment of the tax and legal regimes in this and 40 other offshore jurisdictions, please visit the Lowtax Jurisdictions Guide.



LIECHTENSTEIN

Language -
German, but French and English also spoken

Currency
-
Swiss Franc

Status -
Constitutional Monarchy

Population - 34,247

INCOME TAX
SOCIAL TAXES
CAPITAL GAINS TAX
PROPERTY TAX
Depends on level of taxable income and commune of residence (up to a maximum of 18%)
Employees pay 4.3% of gross pay
Sliding scale, reaching maximum 0.9%
N/A
STAMP DUTY
OTHER TAXES
TAX RESIDENCE QUALIFICATION
BASIS OF RESIDENT TAXATION
N/A
Gift and Estate Tax
Maintaining residence with the intention of staying, or performing activity for monetary gain
World-wide income and wealth
LEGAL BASIS OF RESIDENCE
COST OF RESIDENCE DOCUMENT
WORK PERMIT REQUIRED?
WORK PERMIT AUTHORITY
Residence Permit
N/A
Yes : but EU and EEA country nationals have greater freedom
 


Liechtenstein


Liechtenstein's economic union with Switzerland (established in 1922, and reinforced in 1980), propelled it into rapid financial development. The jurisdiction is most noted for its private banking facilities, but it is also a particularly advantageous location for establishing tax-exempt holding and domiciliary companies, and trusts. Although Liechtenstein is a civil law jurisdiction, there is a trust regime based on common law principles.

Legislation is being discussed to aid the development of the captive insurance and collective investment sectors, but as yet, these have made little impact on the world arena.

This jurisdiction, like many others, has come under international pressure to legislate against money laundering practices, and measures have been taken to ensure greater transparency. Liechtenstein is entering a growing number of Tax Information Exchange Agreements with other countries.

The financial sector is regulated under the Law on Banks and Finance Companies (1993), and the 'Know Your Customer' system is now legally compulsory. There are no exchange controls in Liechtenstein.

Liechtenstein's immigration regulations bear a great deal of resemblance to the Swiss regulations, and a residence permit (obtained from the Aliens Registration Office) is necessary for any non-EEA (European Economic Area) citizen to stay for longer than three months. Work permits are also necessary, although again, EEA citizens will be allowed greater freedom of movement and employment privileges. There are restrictions on foreigners wishing to purchase real estate in Liechtenstein, and tax residence is assumed if:

  • An individual maintains a place of residence with the clear intention that it should be used
  • An individual resides in Liechtenstein and performs any kind of activity for monetary gain.

The jurisdiction is a relatively expensive one in which to conduct offshore business, but resident taxation is moderate, and non-resident and offshore taxation even lower.

The official language of the principality is German, although English and French are also widely spoken. The majority of the newspapers on offer are published in German. The population is predominantly Roman Catholic, and the temperate Alpine climate means that winter sports and cycling are popular.

The tax treatment of retired expatriates resident in Liechtenstein is neither punitive nor particularly appealing, so the draw here will probably be lifestyle-driven as opposed to financial.

For a more detailed treatment of the tax and legal regimes in this and 40 other offshore jurisdictions, please visit the Lowtax Jurisdictions Guide.



LUXEMBOURG

Language - Letzeburgesch is the official language, but French, German and English also widely spoken

Currency - Euro

Status - Constitutional Monarchy

Population - 480,222

INCOME TAX
SOCIAL TAXES
CAPITAL GAINS TAX
PROPERTY TAX
Progressive rates up to 38% plus 2.5% unemployment fund surcharge
Unemployment contributions plus sickness, pension and accident insurance, totaling 14.45% for the employee
Many types of capital gain are subject to regular income tax
There are various taxes on real estate including a 7% tax on transfers
STAMP DUTY
OTHER TAXES
TAX RESIDENCE QUALIFICATION
BASIS OF RESIDENT TAXATION
N/A
'Fortune' tax was 0.5% of final net asset value, but was abolished in 2005
Present for more than 6 months in any tax year
World-wide income
LEGAL BASIS OF RESIDENCE
COST OF RESIDENCE DOCUMENT
WORK PERMIT REQUIRED?
WORK PERMIT AUTHORITY
Provisional Residence Permit
N/A
Yes : For non-EEA nationals
Ministry of Labour


Luxembourg


Luxembourg has a strong private banking sector, due to the absence of withholding tax on interest payments, and strict banking secrecy.

As at January 31st 2009, there were 152 banks registered in Luxembourg, according to the Commission de Surveillance du Secteur Financier (CSSF), which regulates the financial services sector, with assets thought to exceed EUR 1 trillion. The regulatory regime is reasonably relaxed, there are no exchange controls, and banking secrecy actually has a statutory basis in this jurisdiction; it is a criminal offence for bank staff to break these codes unless there is very clear evidence that tax fraud or money laundering activities have taken place. However, like many other jurisdictions Luxembourg is signing an increasing number of Tax Information Exchange Agreements.

Other (related) jurisdictional specialities include:

  • Collective investment funds. The Luxembourg stock exchange specialises in these, and many Luxembourg-registered funds are also listed there.
  • Holding Companies. These are tax exempt vehicles, and are suitable for holding international investment, although are not eligible to trade themselves.

Luxembourg is politically stable, but as a member of the EU, it is in a difficult position, as pressure from the OECD/FATF recommendations conflicts with its reliance on the 'offshore' sector for revenue. Along with the UK and (at times) Austria, Luxembourg resisted the proposed EU withholding tax during 1999 and 2000.

When the EU agreed the Savings Tax Directive in 2003, Luxembourg decided to apply a withholding tax, initially at 15%, now at 20%, on the returns on savings of EU nationals.

In general, for resident individuals, taxes are fairly high, in addition to income tax (rising progressively after a certain income threshold to a maximum marginal rate of around 38%).

EU residents will not need a work permit, but all other expatriates will need to apply (in advance) to the Ministry of Justice for a Provisional Residence Permit, and to the Ministry of Labour for a work permit. If an individual is present in Luxembourg for more than six months, then he/she is assumed to be tax resident, and as such, is liable to tax on world-wide income at the rates mentioned above.

The official language is Letzeburgesch, but French and German are usually used for business and administrative purposes, and English is also spoken. There is one English language newspaper published weekly (although there are German dailies), and 91% of the population are Roman Catholic.

The weather is generally favourable from May to September, with snow likely in the winter months, and the northern (Ardennes) region is usually wetter and colder than the south. Popular pursuits include hiking, water sports, golf, cycling, and wine-tasting.

Due to Luxembourg's high taxation of residents and their wealth, however, this jurisdiction may not be ideal for long term residence during retirement, unless you have been swayed by the idea of wine-tasting, and are really determined that this is where you want to spend your latter years!

For a more detailed treatment of the tax and legal regimes in this and 40 other offshore jurisdictions, please visit the Lowtax Jurisdictions Guide.



MAURITIUS

Language - English, but French and Hindi also spoken

Currency -
Mauritian Rupee

Status -
Independent Commonwealth State

Population - 1,250,882

INCOME TAX
SOCIAL TAXES
CAPITAL GAINS TAX
PROPERTY TAX
A flat tax of 15% from 2008
Pension deductions : Employee pays 3% of earnings
Between 20 and 30% depending on dates of purchase and sale
A National Residential Property Tax applies per square metre to land (MR0.10) and buildings (MR0.30).
STAMP DUTY
OTHER TAXES
TAX RESIDENCE QUALIFICATION
BASIS OF RESIDENT TAXATION
MR15 per sheet on documents connected with property and mortgage transactions
VAT at 15%
Present for more than 183 days in any tax year, or 270 days in total over 3 years
World-wide income (although foreign income only if remitted to Mauritius)
LEGAL BASIS OF RESIDENCE
COST OF RESIDENCE DOCUMENT
WORK PERMIT REQUIRED?
WORK PERMIT AUTHORITY
Residence Permit
N/A
Yes : Issued for 6 months to 3 years
Prime Minister's Office (In association with other authorities)


Mauritius


The financial services sector in Mauritius is a fairly recent development, and as such does not offer the range of services to be found in some other IOFCs. There have, in the recent past, been social tensions in Mauritius, which led to violent demonstrations, but there have been no further incidents of this sort since May 1999. However, the jurisdiction is well placed (between offshore India and Africa) to continue developing further, and the government has shown enthusiasm for e-commerce development, which can only be a good thing.

For individuals, Mauritius specialises at present in offshore trust and company formation, and there are a range of company structures available, including:

  • Offshore Company (now GBC Category 1)
  • International Company (now GBC Category 2)
  • Limited Life Offshore Company
  • General Partnership
  • Limited Partnership.

The domestic and offshore sectors of the Mauritian economy are quite firmly separated, and domestic taxation is moderately high. However, Mauritius was one of six offshore jurisdictions which signed 'commitment' letters to the OECD in 2000. Partly as a result of this commitment, the Government passed a range of replacement legislation in 2001 including the Financial Services Development Act 2001, which set up a Financial Services Commission to replace MOBAA. Most existing offshore legislation was 'grandfathered' into the new regime.

There are no longer any exchange controls (they were finally abolished completely in 1994), but investors are still required to demonstrate the source of funds to be repatriated, and must make sure that they are completely up to date with local taxes.

In terms of banking, the Mauritian authorities have been very cautious about offshore banking development, and as a result, there are only ten Offshore Banking Units (OBU) established. The licensing process is rigorous, and the regulatory regime quite strict.

Nationals of OECD member countries do not require a visa to enter Mauritius, and are initially allowed to stay up to six months. All other foreign nationals will need a visa, which is free, but can take up to a month to process.

The Mauritius Financial Services Commission makes recommendations for non-Mauritian citizens seeking employment, and also deals with the issuance of residence permits (although both are actually granted by the Prime Minister's Office, in association with the Ministry of Human Resource Development). The two permits can usually be processed concurrently by the FSC, and with the minimum level of disruption to the expatriate, who just needs to provide them with the application forms, and relevant documentation (including a letter of sponsorship from the prospective employer).

Tax residence is assumed if an individual is present for more than 183 days in any one tax year, or 270 days in total over 3 years, and if this is the case, then they will be taxed on their world-wide income, although only if the foreign income is received in Mauritius. There are some tax breaks available for employees of offshore operations, but overall, not a great deal of distinction is made. Non-Mauritian citizens are required to seek permission from the Prime Minister's Office before they can purchase property locally.

The official language of Mauritius is English, although French and Hindi are also widely spoken, and there are several daily newspapers in circulation, the majority of which are published in French. The population is predominantly Hindu (51%), and there are also Christian and Muslim communities established, accounting for 31% and 17% of the population respectively. There is very little seasonal variation in Mauritius, with the weather generally warm all year round, and water sports and golf are the most popular pursuits.

Although Mauritius might be considered eminently suitable for the establishment of an offshore company or trust, whether for the purposes of streamlined financial management or asset protection, its suitability as a retirement destination must be questioned. High domestic taxation for residents, and the very rigid distinction between offshore and onshore in this jurisdiction could mean that any advantages gained by basing your assets here originally may be lost by residing here during your retirement years.

For a more detailed treatment of the tax and legal regimes in this and 40 other offshore jurisdictions, please visit the Lowtax Jurisdictions Guide.



MONACO

Language -
French, Monegasque, Italian, and English

Currency -
Euro

Status - Constitutional Monarchy

Population -32,671

INCOME TAX
SOCIAL TAXES
CAPITAL GAINS TAX
PROPERTY TAX
N/A except for French nationals
Employee pays 10-14%
N/A
7.5% stamp duty on registered value of real estate sold
STAMP DUTY
OTHER TAXES
TAX RESIDENCE QUALIFICATION
BASIS OF RESIDENT TAXATION
7.5% on registered value of business sold, lower for other types of transaction
Inheritance and gift tax : Except for spouses, parents and children
N/A
French nationals pay income tax
LEGAL BASIS OF RESIDENCE
COST OF RESIDENCE DOCUMENT
WORK PERMIT REQUIRED?
WORK PERMIT AUTHORITY
Residence Permit
N/A
Yes : For non-French nationals
 


Monaco


Monaco has no desire to be considered as a 'tax haven', and as such, the extent of offshore services offered is limited; the jurisdiction is best known for the range and quality of private banking services offered to wealthy individuals, although the commercial banking sector has undergone significant development of recent years.

There are some 70 banks and financial institutions established in the principality, and it is interesting to note that approximately 85% of those banks' clients are non-resident in Monaco. The banking sector has a secure legislative base, and is regulated by the Bank of France - because of the close relationship between the two countries, the legal basis of banking in Monaco owes much to French banking law. Banking secrecy in Monaco is adequate for those with no French connection, but is otherwise compromised by the close relationship of the two systems.

There are no exchange controls, as the jurisdiction has a monetary union with France. Only French nationals pay (French) income tax in Monaco, but all employees in Monaco pay hefty social insurance contributions, which can offset the advantageous income tax situation. There is no capital gains tax.

Non-French nationals will need a residence permit and in order to acquire this, the expatriate must present himself at the police station local to his intended residence, with documents demonstrating sufficient income to support himself and dependants during the intended period of residence. The application will usually take 45 days to process, and is initially valid for one year, and renewable at three-yearly periods thereafter. Once residence has been constant for nine years, then a ten-year permit can be applied for, after which citizenship is an option.

A work permit is also necessary for non-French nationals seeking employment, and the documentation required for this includes a visa application, contract of employment, and evidence of a fixed address in Monaco. There is no quota system in place for the issuing of work permits, and although they are not hugely difficult to obtain, government policy generally gives priority to French nationals and citizens of Monaco.

As previously mentioned, only French nationals are liable for income tax (which is paid directly to the French Government), and therefore, residence for taxation purposes is not really an issue in this jurisdiction. There are also no restrictions on the purchase of real estate by foreign nationals.

For business transactions, and in day to day life, French, Italian, and English are most commonly spoken, although there are groups that speak Monegasque. There is one English language magazine available, but there are a number of newspapers published daily in French covering Monaco related news. The majority of the population is Roman Catholic, with small pockets of Anglicanism. Monaco is renowned for water sports, and also of course for the casinos which are established there.

Due to the high social insurance contributions levied on all Monaco-based employees, this jurisdiction may not be the ideal location for you during your working life as an expatriate. However, if you have accumulated a substantial net worth, and are looking for a pleasant location to spend your retirement, provided you have no French connections, Monaco may be just the place!

For a more detailed treatment of the tax and legal regimes in this and 40 other offshore jurisdictions, please visit the Lowtax Jurisdictions Guide.



Netherlands Antilles

Language - Dutch, but Spanish, English, and Papiamento also spoken

Currency -
Netherlands Antilles Florin

Status -
Part of the Kingdom of the Netherlands (but full autonomy in internal affairs)

Population - 223,652

INCOME TAX
SOCIAL TAXES
CAPITAL GAINS TAX
PROPERTY TAX
Progressive to 39% (Excluding Island surcharge)
Employees contribute 1.5% of taxable pay, employers contribute 0.5%
Capital gains are normally taxed as regular income
0.5% p.a levied on unimproved property, 0.6% on value of improved property. Annual occupancy tax : 5% of rental value
STAMP DUTY
OTHER TAXES
TAX RESIDENCE QUALIFICATION
BASIS OF RESIDENT TAXATION
Buyers of real estate pay a 4% transfer tax
Inheritance and Gift Taxes
Permanent home located there, habitual place of residence, or centre of social and economic interest
World-wide income
LEGAL BASIS OF RESIDENCE
COST OF RESIDENCE DOCUMENT
WORK PERMIT REQUIRED?
WORK PERMIT AUTHORITY
Residence Permit
Varies according to nationality
Yes
Governor's Office


Netherlands Antilles

Although the Netherlands Antilles are composed of two groups of islands, the majority of offshore business takes place on Curacao, where the professional and financial infrastructure is more highly developed.

The jurisdiction is particularly well equipped to deal with the following offshore sectors:

  • Banking
  • Mutual Funds. (Netherlands Antilles NVs are particularly suited to US professional investors, as they have been accepted under the IRS 'check the box' regulations and can effectively be treated as limited partnerships for US tax purposes.)
  • Insurance
  • Financial holding companies

In the banking sector, a distinction is made between 'Consolidated International Banks' (which are usually branches or subsidiaries of the world's top 1000 banks, and as such are sufficiently regulated by their parent company), and 'Non-consolidated International Banks' which are usually owned by a non-financial institution, and are primarily regulated by the Central Bank. Onshore banks and offshore banks are also divided, and offshore banks are only allowed to conduct external business. In 2005 in the Netherlands Antilles, there were about 11 onshore banks and about 40 offshore banks, with assets amounting to about NaF80bn.

There is no banking secrecy legislation as such, but beneficial company ownership does not have to be disclosed, and the islands have come under increasing international pressure to legislate against drug-related financial transactions, due to their location, which has left them vulnerable to this type of money laundering. Measures to deal with this type of laundering have been instituted with some degree of success.

The taxation regime for residents is quite high, with offshore taxation light, but not minimal. The New Fiscal Framework, intended to improve the jurisdiction's standing as an IOFC, has removed the distinction between offshore and onshore companies, simplified tax rates, and introduced a withholding tax. In order to achieve exemption from exchange controls, a license needs to be obtained from the Central Bank, and in some cases, a licensing fee of 1% is levied.

For those without Dutch nationality, a residence permit must be obtained, and the potential expatriate must present his passport, a certificate of good behaviour from the local police force in the previous country of residence, evidence that he will be able to support himself and any dependants (if a work permit is not being applied for), and any documents pertaining to family members expatriating with him. In addition to this, a refundable deposit (with the cost varying according to country of origin) must also be paid.

The job of applying for a work permit falls to the prospective employer, who must be provided with the following documents by the expatriate:

  • Passport copy
  • Photographs of the expatriate
  • Medical Certificate
  • Certification of good behaviour (as before)

The potential employer must also prove that the position was advertised locally, but that no one suitably qualified was found to fill it.

Tax residents of the Netherlands Antilles are liable for tax on their world-wide income, and this type of residence is assumed if any of the following are true:

  • The individual has their permanent home on one of the islands
  • It is their habitual place of actual residence
  • It is the centre of their economic or social interest.

Since 1987 (with amendments in 1997) the Netherlands Antilles offers a favourable personal tax regime for retired people. The regime is available on the following conditions:

  • The "penshonado" should be at least 50 years old on the date that he registers himself as a resident;
  • The pensioner should not have lived in the Netherlands Antilles in the five years before making the application for 'penshanado' status;
  • The pensioner must own a house in the Netherlands Antilles with a value of at least USD253,000 for his personal use and available to him within 18 months after his registration as a resident;
  • The application for favourable tax treatment must be filed within two months after registration as a resident;
  • The "penshonado" has to provide employment to at least one employee for not less than 30 hours per week.

A "penshonado" may choose between two tax regimes:

  • Worldwide income, not derived from business or employment within the Netherlands Antilles, including pension-rights of which at least 70% are externally funded, will be subject to a 10% Antilles income tax rate. Capital gains on portfolio investments are not considered taxable income under Netherlands Antilles tax law. Netherlands Antilles source income will be subject at the ordinary Netherlands Antilles personal income tax rates (with a maximum of 39% on taxable income exceeding NAF 109,000; or
  • All foreign income will be fixed at USD281,000 and taxed at the normal progressive rates, which amounts to an effective tax of US$152.000.

Foreign income is considered to be all income from a foreign source, including non-resident (so called "offshore") companies established in the Netherlands Antilles, all income from savings at local banks; and the rental-value of the house owned by the penshonado.

"Local" income is all income that the penshonado receives from employment in a company established in the Netherlands Antilles in which he owns 40% or more of the capital stock and/or income obtained as a director or officer of a company and/or income received from bonds issued by a local company. Local income is taxed at the normal tax-rate for local citizens. The penshonado may not enter into employment with a company in which he does not own at least 40% of the capital-stock.

The language most often used for business and day to day purposes is Dutch, although English, Spanish and Papiamento are also spoken, and most of the islands publish at least one daily newspaper, with the exception of Saint Eustatius. Saint Maarten is predominantly Protestant, but the rest of the islands have larger Roman Catholic communities.

The standard of leisure pursuits available varies widely across the islands, although the climate for all is dry and sunny, and water sports, cycling and gambling appear to be a constant.

The islands making up the Netherlands Antilles are currently undergoing fundamental constitutional change. Following a series of referenda between 2000 and 2005, a Round Table Conference held between the governments of the Netherlands, Aruba and the islands of the Netherlands Antilles agreed that Curacao and St Maarten would become autonomous territories, while the BES islands of Bonaire, St. Eustatius and Saba would have a new status, but remain linked to the Netherlands. The agreement will dissolve the Netherlands Antilles in 2010.

For a more detailed treatment of the tax and legal regimes in this and 40 other offshore jurisdictions, please visit the Lowtax Jurisdictions Guide.



SEYCHELLES

Language - English, French, and French based Creole

Currency - Seychelles Rupee

Status - Independent Republic and member of the Commonwealth

Population - 81,895

INCOME TAX
SOCIAL TAXES
CAPITAL GAINS TAX
PROPERTY TAX
N/A
Employee pays 2.5% of salary, employer pays on sliding scale between 35-40% of salary
N/A
N/A
STAMP DUTY
OTHER TAXES
TAX RESIDENCE QUALIFICATION
BASIS OF RESIDENT TAXATION
N/A
N/A
Present for more than 180 days
Territorial Basis
LEGAL BASIS OF RESIDENCE
COST OF RESIDENCE DOCUMENT
WORK PERMIT REQUIRED?
WORK PERMIT AUTHORITY
Gainful Occupation Permit
Gainful Occupation Permit costs USD360 per year
Yes : GOP
Seychelles Government


Seychelles

The offshore financial sector of the Seychelles economy has been fostered and encouraged by the government over the last twenty years, and as a result, has been steadily developing, with recent, well formed legislation now in place for:

  • International Business Companies
  • Offshore Banks
  • Insurance Companies
  • Trusts

In addition, enabling legislation for mutual funds was put in place by the Seychelles government in 1997.

The financial sector is regulated by the Offshore Banking Department of the Central Bank, and at present there are five licensed foreign banks, and two domestic banks established in the Seychelles.

This jurisdiction operates a territorial taxation system, meaning that only income arising there is taxed, and although there are import duties to be paid, these have been reduced substantially in recent years, which combined with the large number of investment incentives for incoming investors, means that the Seychelles are an attractive option. There are no exchange controls.

In order to obtain residence in the Seychelles, an individual must either be able to demonstrate sufficient resources to support themselves and their dependants, or must obtain a Gainful Occupation Permit (GOP) from the government. A GOP must be applied for by the prospective employer, and although it acts as permission for both residence and employment, there is an annual charge per person. A reduced rate is sometimes available for investors approved under the Investment Promotion Act, but there is usually quite a low limit on how many foreign nationals can be employed by any one company.

Residence for taxation purposes is not really an issue in the Seychelles, because as previously mentioned, there is no income tax as such, and taxation is levied on a territorial basis.

French, English and Creole are the most commonly spoken languages on the islands, which are predominantly Roman Catholic, and there are daily, weekly, and monthly English language newspapers available. The climate is tropical, with monsoon rains generally falling between November and February. Despite this, outdoor pursuits such as diving, snorkelling and fishing prove popular with locals and expats alike.

Due to the aforementioned territorial taxation system, expatriates wishing to live in the Seychelles after retirement would be well advised to consider locating pensions and other investment elsewhere prior to taking up residence, as investment income not located in or arising from the jurisdiction will receive more favourable treatment.

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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