Dirt88gray: Hong Kong Banks Compete For Offshore Renminbi

2018-03-16T14:52:31Z

Hong Kong Banks Compete For Offshore Renminbi

Dirt88gray: Hong Kong Banks Compete For Offshore Renminbi

2018-03-16T14:46:32Z

Hong Kong Banks Compete For Offshore Renminbi

Нова сторінка

UK

Ireland (though not often)

Isle of Man

Jersey

Guernsey

Malta

Estonia

Latvia

Cyprus

Switzerland

Lichtenstein

Netherlands

Luxembourg

Gibraltar
There are lots more but I can't think of any reason you'd want to use any of the others when you've got those to choose from and frankly there are definite preferences among those depending on what you're doing. We'll cover each in detail in coming posts but for today we're going to focus on Gibraltar. As it stands today as of this writing we LOVE Gibraltar. But when I first started studying offshore jurisdictions I didn't quite understand why I would love it in spite of it being mentioned to me by several people.On the surface Gibraltar isn't that spectacular:

While supposedly inexpensive by European standards Gibraltar company formation or incorporation typically costs around 850 GBP in the retail market not counting other required documents

There's a 10% tax rate and no tax treaties

Company formation takes a minimum 2 weeks often dragging on much longer

Director/ownership details are public

There's no domestic corporate banking to speak of

Over a certain level audited financials are required
Reading the list it doesn't sound that compelling to me and unless there are special circumstances I'd say if you're going to form a resident Gibraltar company you're probably better off looking elsewhere (alternatives discussed in other posts). It used to be that Gibraltar being an EU member but not a member of the VAT regime was helpful but updates to the VAT regime have mostly eliminated these benefits.Favorable Tax TreatmentHowever, Gibraltar is one of only 3, really only 2, jurisdictions within the EEA (European Economic Area) with a particular nuance in their corporate residency laws. Tax residency in Gibraltar is based ONLY on management and control, which means you can have a non-resident Gibraltar company. What does that mean?A non-resident company isn't liable for any local income taxes except on domestic source income (no income in Gibraltar = 0% corporate tax rate). So we've just gone from Gibraltar being a 10% tax jurisdiction, which is OK, but not exceptional, to a fantastic 0% tax regime.

Non-resident Gibraltar companies also benefit from not having the same requirements when it comes to the likes of audited financial statements that resident companies have.Non-Residency RequirementsBy default a Gibraltar company is not non-resident so to ensure it is you need to file according with the local financial authority and meet the appropriate criteria. These include:

No funds remitted to Gibraltar

No business in Gibraltar or from Gibraltar sources (not a big deal since it's a tiny market of around 80 000 people)

Management and control (generally speaking directorship of the company) outside of Gibraltar
This does raise some questions such as:

If no funds can be remitted to Gibraltar (there's a sort of remittance basis in their tax system) where should the company bank?

If management and control isn't in Gibraltar where should it be?
Banking & ReputationCorporate banking in Gibraltar is virtually non-existent anyway, while Gibraltar is fairly well known for some of their banking it is private banking not corporate banking and certainly not for small businesses.

@@ Рядок 1: / Рядок 1: @@
-UK
+Thus, a Hong Kong offshore company that generates income from abroad practically pays Zero tax. Overseas profits are exempt from taxation in Hong Kong even if it is brought back to the jurisdiction.Even for revenue generated from Hong Kong the tax applicable on taxable profit is just 16.5%, one of the lowest in the region. After deductions and exemption the effective tax rate will be much lower than the headline tax rate.Positive Image: Hong Kong Companies are not perceived as offshore tax haven as Hong Kong is not regarded as a tax shelter. In an article published in May 2009, the Director of the OECD's Centre for Tax Policy and Administration commended Hong Kong's efforts to comply with the international standards on tax transparency and exchange of information while pointing out that Hong Kong is not a tax haven according to the OECD criteria. Subsequently, in its September 2009 report, the OECD vindicated again that Hong Kong is not a tax haven and recognised Hong Kong's commitments to the OECD standards. Therefore a Hong Kong Offshore company commands a respectable image and does not raise suspicions.
-Ireland (though not often)
+Strategic Location: Hong Kong is considered as the gateway to China, the world's biggest market and facilitates easy access to mainland China and all the key markets of Asia, most of the Asian cities are within four hours flying radius.Free economy: Hong Kong is regarded as the world's most free economy with the lack of restrictions and government interventions in trade. The economic policy allows free inflow and outflow of capital and there is no exchange control. The jurisdiction allows 100% foreign ownership of companies. It has been ranked as the freest in the world by the Index of Economic Freedom for 15 consecutive years.Political Stability: Hong Kong a former British Dependent Territory became a Special Administrative Region of People's Republic of China in July 1997. Since then Hong Kong has retained its autonomous status and under the "one country two systems" concept, the Chinese government does not interfere with the governance of Hong Kong which has flourished by leaps and bounds with a significant share of world's largest banks, corporations and high net worth individuals. World Investment Report 2009 released by the United Nations Conference on Trade and Development (UNCTAD)reaffirmed Hong Kong as one of the world's and Asia's most attractive destinations for FDI. Despite the tough economic situation Hong Kong attracted US$63 billion inward investment in 2008 and continues to be Asia's second largest and is the world's seventh largest FDI recipient. This reflects on the investment climate and investor's confidence which are direct outcome of Political stability.Strong Economy: With 7 million population and foreign exchange reserve of over US$140 billion the economy of Hong Kong is resilient and vibrant. The Hong Kong Stock Exchange is Asia's second largest stock exchange in terms of market capitalization, behind the Tokyo Stock Exchange. As of 31 December 2007, the Hong Kong Stock Exchange had 1,241 listed companies with a combined market capitalization of $2.7 trillion.Absence of Nationality or Residency Limitation: As an international business center the jurisdiction does not have any stipulation regarding the nationality or the residency of share holders and directors.
-−
-Isle of Man
-−
-Jersey
-−
-Guernsey
-−
-Malta
-−
-Estonia
-−
-Latvia
-−
-Cyprus
-−
-Switzerland
-−
-Lichtenstein
-−
-Netherlands
-−
-Luxembourg
-−
-Gibraltar
-There are lots more but I can't think of any reason you'd want to use any of the others when you've got those to choose from and frankly there are definite preferences among those depending on what you're doing. We'll cover each in detail in coming posts but for today we're going to focus on Gibraltar. As it stands today as of this writing we LOVE Gibraltar. But when I first started studying offshore jurisdictions I didn't quite understand why I would love it in spite of it being mentioned to me by several people.On the surface Gibraltar isn't that spectacular:
-−
-While supposedly inexpensive by European standards Gibraltar company formation or incorporation typically costs around 850 GBP in the retail market not counting other required documents
-−
-There's a 10% tax rate and no tax treaties
-−
-Company formation takes a minimum 2 weeks often dragging on much longer
-−
-Director/ownership details are public
-−
-There's no domestic corporate banking to speak of
-−
-Over a certain level audited financials are required
-Reading the list it doesn't sound that compelling to me and unless there are special circumstances I'd say if you're going to form a resident Gibraltar company you're probably better off looking elsewhere (alternatives discussed in other posts). It used to be that Gibraltar being an EU member but not a member of the VAT regime was helpful but updates to the VAT regime have mostly eliminated these benefits.Favorable Tax TreatmentHowever, Gibraltar is one of only 3, really only 2, jurisdictions within the EEA (European Economic Area) with a particular nuance in their corporate residency laws. Tax residency in Gibraltar is based ONLY on management and control, which means you can have a non-resident Gibraltar company. What does that mean?A non-resident company isn't liable for any local income taxes except on domestic source income (no income in Gibraltar = 0% corporate tax rate). So we've just gone from Gibraltar being a 10% tax jurisdiction, which is OK, but not exceptional, to a fantastic 0% tax regime.
-−
-Non-resident Gibraltar companies also benefit from not having the same requirements when it comes to the likes of audited financial statements that resident companies have.Non-Residency RequirementsBy default a Gibraltar company is not non-resident so to ensure it is you need to file according with the local financial authority and meet the appropriate criteria. These include:
-−
-No funds remitted to Gibraltar
-−
-No business in Gibraltar or from Gibraltar sources (not a big deal since it's a tiny market of around 80 000 people)
-−
-Management and control (generally speaking directorship of the company) outside of Gibraltar
-This does raise some questions such as:
-−
-If no funds can be remitted to Gibraltar (there's a sort of remittance basis in their tax system) where should the company bank?
-−
-If management and control isn't in Gibraltar where should it be?
-Banking &amp; ReputationCorporate banking in Gibraltar is virtually non-existent anyway, while Gibraltar is fairly well known for some of their banking it is private banking not corporate banking and certainly not for small businesses.

Hong Kong Banks Compete For Offshore Renminbi - Історія редагувань

Dirt88gray: Hong Kong Banks Compete For Offshore Renminbi

Dirt88gray: Hong Kong Banks Compete For Offshore Renminbi