Company Activities

A holding company can be established and used to hold the shares of subsidiaries located in high tax countries. Most high tax countries require tax to be withheld on dividends to be paid to non-residents, so attention should be paid to the availability of the double-tax-avoidance treaty between the country where the subsidiary is located and where the holding company is established. Where a person is domiciled outside the territory and owns assets located in that territory (for instance, property), then such assets may be protected against inheritance tax and higher rates of taxation by holding the assets through an investment company. A high net worth individual with properties or other assets in a number of countries may wish to hold these through the medium of a personal holding company so that upon his demise the need to obtain probate in each country is avoided. This saves legal fees and avoids publicity. Many of the difficulties and expenses associated with an investment in overseas property, such as holiday villas, may be avoided through the use of a company to hold the title of the property. Sales of the property at a future date can be dealt with quickly and easily by the sale of the company shares to the purchaser. This also saves legal fees and overseas transfer and value-added taxes levied by certain foreign countries. It can also be used to successfully avoid capital gains and inheritance taxes. If a holding company is registered in a suitable jurisdiction with appropriate double-tax avoidance treaties in place with the owners' home jurisdiction, such holding company may be used to hold shares in various trading companies owned by the same owner. Such layout would provide for fully or nearly tax-free repatriation of trading profits directly to the beneficial owner of the companies.
The use of shipping companies can eliminate direct or indirect taxation on shipping. Such companies may own or charter ships and accumulate the profits from these activities tax-free. Ships or yachts may be owned by a company and registered in an offshore jurisdiction, in a cheaper and more tax efficient method of ownership.
A company can purchase or be assigned the right to use a copyright, patent, trademark or know-how by its original holders, with a power to sub-license and subsequently exploit the intellectual property rights in various countries. Such arrangements must be properly planned, as many high-tax countries impose withholding tax at source on royalty payments. Existence of a double-tax-avoidance Treaty between the countries involved may reduce such withholding tax. A company can be used by internet-businesses to hold domain names and operate websites in a tax-free environment.
Private funds pooled through an investment company can be put into investment instruments throughout the world, accumulating the returns and capital gains in a tax-free environment. Using a private investment company would provide additional confidentiality for the investors and tax benefits for the investment returns. While investments in many high tax countries would be subject to withholding tax at source or capital gains, there are still plenty of investment instruments where no such taxation would be applicable. Returns accumulated in a tax-free area would add flexibility to their distribution and re-investment.
A freelance international contractor, consultant, designer or other professional individual working for a fee can reduce his tax burden by incorporating a company, through which the fees for his contracts are routed. While the professional himself would receive a fixed level of taxed remuneration (salary) from his company, the bulk of the fee income would accumulate in the name and accounts of the company, in a tax-free environment. Designers, authors, consultants and entertainers may assign or contract with a company the right to receive fees due under a contract for services. A further advantage of a professional services company is that potential liabilities, associated with a professional services contract, would fall upon the company, not the individual.
A company may act as a trading intermediary – sales, distribution or import-export company. The company would typically buy directly from the manufacturer or wholesaler and arrange the goods delivered directly to the end-customer from the place of production or purchase. This can be of particular interest where goods originate from one country, are sold in another, yet the principal is located in a third country. A procurement company can be used by a domestic importer to source goods abroad, or a sales company can be used by a domestic producer to distribute the goods. The profits arising on the difference between purchase and sales price may be accumulated in a tax-free environment. Such profits can be re-invested into further development of the business, without incurring any excess tax liability.