Commentary: The changing landscape |
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| Dr. Trevor A. Carmichael, QC, Chancery Chambers, Bridgetown, Barbados | |
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Latin Letters: Perilous Journey |
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| Derek Sambrook, FIBSA, TEP, Managing Director, Trust Services, S.A., Panama, Republic of Panama | |
| Argentina, Brazil and Chile walk on a tightrope trying to keep their economic balance and, so far, there has been a safety net of low US dollar rates and Chinese demand. Derek Sambrook considers how secure this safety net really is.
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Forced heirship and Scottish trusts |
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| Alison Paul, Turcan Connell, Edinburgh, Scotland | |
| Forced heirship has been described as the means by which a state imposes control over an individual’s power to make testamentary dispositions – if the settlor of a trust dies under a system which includes forced heirship his heirs may have grounds to attack the trust. Alison Paul considers how, through the use of the Scottish trust, such forced heirships claims can be defeated and how that trust can remain in existence forever.
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Offshore structures for South Africa - maintaining trust integrity |
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| Dewald Joubert, Senior Assoicate, Maitland, Isle of man | |
| Before the liberalisation of the South African economy many South Africans had established offshore asset holding structures in contravention of exchange controls. Dewald Joubert examines the tax and exchange control amnesty in 2003 and its success or otherwise. He also considers the more significant long-term consequences arising from the tax changes there.
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Argentina: Robust transfer pricing regime |
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| Martin A. Litwak, Walker Smiths, Tortola, British Virgin Islands | |
| Tax authorities in Argentina have been concerned about international tax avoidance techniques based on transfer pricing for a long time and has developed different approaches to reduce its tax revenue exposure to transfer pricing. Martin Litwak examines the main features of the regime currently in force in Argentina.
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Luxembourg: The law relating to securitisation |
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| Jean-François Bouchoms, Allen & Overy, Luxembourg | |
| The Luxembourg Parliament has recently introduced a new legal, regulatory and tax framework for Luxembourg securitisation vehicles. Jean-François Bouchoms examines the new law and considers the legislation in detail.
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Cyprus and its importance for international business |
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| Antonis Kassapis, BSc FCA, Senior Consultant, A.K. Cosmoserve Ltd, International Business Consultants, Cyprus | |
| Antonis Kassapis considers the new and positive benefits introduced by Cyprus in compliance with EU law, OECD and FATF requirements, in contrast to what has been perceived as negative changes such as the increased corporation tax rate for international businesses.
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Quality buiness horizons with a fledgling EU member |
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| Mike Davies, Trident Trust, Limassol, Cyprus | |
| Despite years of international perception as an “offshore tax haven”, Cyprus is recreating its image as an onshore jurisdiction within the EU with many of the factual advantages traditionally associated with offshore regimes. Mike Davis considers how Cyprus has and will evolve as a member of the EU.
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The Private foundation – a particular asset protection vehicle |
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| Ramses Owens, Attorney-at-Law – Associate, Mossack Fonseca & Co, Panama, Republic of Panama | |
| The purpose of asset protection, both domestic and offshore, is to preserve a client’s wealth. Ramses Owens considers the Panamanian foundation and how it can be used as an asset protection vehicle.
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The Dutch connection |
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| Leo Neve, Neve Tax Consultants, Barendrecht, The Netherlands | |
| The Netherland Antilles introduced the New Fiscal Regime, a system which draws no distinction between offshore and onshore companies, in 2001. Leo Neve considers the impact the Regime has had on the jurisdiction as an international financial center over the last three years.
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The Brazilian Blacklist: A brief analysis |
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| Ricardo Fischer, LLM, Attorney-at-Law, Brazil; and Suzana Gastaldi, Law Student - UFSC, Brazil | |
| In 2002 Brazil issued its third blacklist that lists 53 countries and territories that have favored taxation and/or ensure secrecy related to the composition of legal entities. However, the lack of a revision of the blacklist has caused considerable losses for the listed jurisdictions as well as for the Brazilian private sector interested in establishing economic relations with these countries. Ricardo Fischer and Suzana Gastaldi examine the implications for those listed jurisdictions.
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Creating a more business friendly environment |
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| Jack W. Flader, Jr., Managing Director and General Counsel and Susan Kwan, General Manager- Company Secretary Department, Zetland Financial Group | |
| In July 2003, Hong Kong passed the Companies (Amendment) Ordinance 2003, which amended the Companies Ordinance of Hong Kong. Jack Flader and Susan Kwan outline briefly several of the most important elements of the Amendment Ordinance, and discuss its impact, particularly in relation to the Closer Economic Partnership Arrangement between Hong Kong and the People’s Republic of China.
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Residency & Citizenship: Tax-advantage residence in Switzerland |
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| Christian Kälin, Henley & Partners Switzerland, Zurich | |
| Switzerland’s political and economic stability, combined with excellent communications and transport links, efficient public services, and low tax rates make it the ultimate choice, both for business and residence. In the continuing Offshore Investment Residency & Citizenship series, Christian Kälin considers the legal and tax implications for an individual choosing to take up residency in Switzerland.
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A Letter from St. Thomas: Hedge fund management fees - in the IRS cross hairs |
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| Denis A. Kleinfeld, St.Thomas, US Virgin Islands | |
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