EXPERT INSIGHTS

Nigel Morris-Cotterill, Head of The Anti Money Laundering Network, on the nuances of offshore confidentiality laws. In a previous article, (Offshore and "offshore" - Asia Outbound, Autumn 2010) we looked at how money laundering is defined, how it relates to predicate offenses and how, by linking offenses and laws in two countries, prosecutors may apply for the extradition of a banker or provider of professional services from one jurisdiction to another, not as a conspirator or an accomplice but as a principal in the offense of money laundering. In this article, we will look at one of the reasons the...

EXPERT INSIGHTS 2020

Michael Wong and Jonathan Tjia from KPMG discuss PRC tax considerations for China outbound investment In the current economic environment, tax considerations are becoming increasingly important in the assessment of potential investment opportunities. It is with this in mind that organizations and investors around the world look to design appropriate holding, financing and operating structures to take advantage of tax concessions, incentives and agreements to legitimately minimize the overall effective tax rate on their global earnings. This article focuses on some of the key PRC tax regulations that need to be considered to ensure that you reap the benefits of any offshore structuring,...

EXPERT INSIGHTS 2020

Michael Liu of CIL Partners on how Chinese e-commerce companies are finding offshore destinations an excellent place for some of their onshore services, including warehousing, data centers and international logistics Online resellers have been doing brisk business as of late, and Chinese tax authorities have taken notice. In July2010, Chinese Customs lowered the threshold necessary to waive a tax on products mailed by individuals from overseas from a duty of RMB 500 (US$ 73.35) to RMB 50. This move was followed in August, by a strictly levy on products with value exceeding RMB 5,000 brought into China by individuals for...

EXPERT INSIGHTS 2020

Leah Scott of Appleby discusses how to structure investments into Africa so they are tax-efficient and safe When a foreign multinational decides to expand its foreign investments into Africa, it often considers using an offshore holding company in a jurisdiction with a good tax treaty network with African countries, in order to help reduce withholding taxes on dividends, interest and royalties, and in some instances, gains subject to tax, in the counterparty territories. Mauritius, with its modern democracy and its established track record of political stability, is a proven route for international investors wanting to do business in Africa. Mauritius has...

EXPERT INSIGHTS 2020

Bobby Brantley explains what recent OECD rulings mean for offshore finance centers September 2009 was a month loaded with headlines coming out of the G20 meeting and following the OECD lobal Tax Forum on Transparency and Information Exchange for Tax Purposes meeting later that month. As in 2000, a new list was released which was this time focused on the number of bilateral agreements containing exchange of information (EOI) clauses meeting the OECD standard the country had in place. An arbitrary minimum number set at 12 was used to determine whether the jurisdiction had ubstantially implemented the nternationally agreed tax...

EXPERT INSIGHTS 2020

By David Sucre Levy Since Spanish colonial times in America, Panama has always been seen as a strategic and logistical point to the arrival of settlers on this continent and for the development of their business. Today, centuries later, the Panamanian government has created incentives, laws and special areas to continue attracting international companies to settle on its territory and to use it as a commercial platform in the Americas. Chinese companies should take advantage of this invitation, or at least assess the benefits deriving from establishing themselves in the Republic of Panama as a strategic point for the growth...

EXPERT INSIGHTS 2020

Leah Scott, an associate at Appleby Bermuda and Seychelles, says that in light of China new tax regulations, companies may need to consider restructuring their special purpose vehicles to achieve greater tax efficiency.In December 2009, the State Administration of Taxation passed Circular 698, a new regulation regarding the taxation of non-resident enterprises. Circular 698 is based on the Enterprise Income Tax Law of The People Republic of China, and (EIT) covers taxation of non-resident equity transfer income, specifically targeting offshore transactions involving the indirect transfer of shares in resident Chinese companies. A typical offshore structure consists of a parent company,...

EXPERT INSIGHTS 2020

Leah Scott, an associate at Appleby Bermuda and Seychelles, says that the island is on track to becoming the destination of choice for Chinese investors. Seychelles is an island with exceptionallystrong links with China,both in terms of politics and economics. And it is easy to see why, as the Seychelles/China double taxation agreement(DTA) is one of the best tax treatiesin the world. It allows a tax resident Company Special License (CSL) to payjust 1.5% on its income tax worldwide,which can be further reduced to 0% after allowance for foreign tax paid. But it is not just as a resident for...

EXPERT INSIGHTS 2020