Hong Kong Banks Compete For Offshore Renminbi

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.