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US Government Introduce a Five-Million-Dollar Incentive to Move Offshore

One of the reasons that you won’t often find me commenting on US tax issues is that the US government have a lot of very nasty laws that they are prepared to use on anyone they think might be encouraging their citizens to evade or even just avoid tax – even though tax avoidance is [...]

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A Most Unlikely Freedom Haven

I think it’s imperative that people get off their butts and travel. I say this because I believe the old dictum that travel broadens the mind. And what this world needs more than anything else right now is “mind broadening”. Travelling to a country gives you a chance to experience life as others live it, [...]

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What Will Vince Cable Do Now For The Isle of Man?

Just over a year ago I wrote about the visit to the Isle of Man undertaken by Vince Cable, then Liberal Democrat Shadow Chancellor who today was appointed Secretary of State for Business and Banking in the new Conservative – Liberal cabinet. Despite having been a stern critic of the island, calling it a tax [...]

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What Is the Difference Between Residence and Domicile?

One thing that can be clearly seen amid all the arguments over the status of Lord Ashcroft is that neither the press nor the politicians really understand the difference between someone being resident in the UK or being domiciled in the UK. It is rather painful to listen to the claim and counterclaim of so [...]

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What Is Transfer Pricing?

“Transfer pricing” is an increasingly important and contentious area of international tax law. This is because so much of modern world trade involves the transfer of goods, intangibles or services within multinational enterprises (MNEs) – groups of companies or related businesses based in 2 or more countries. Such international trade offers scope for an MNE [...]

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Last Desperate Attempt by a Bankrupt Government

In what may be seen as a final act of desperation by a morally, legally and financially bankrupt UK government, the Treasury, having failed to “crack down” on what it sees as tax avoidance by banks (the UK courts don’t agree with HMRC) has now come out with a “Voluntary Code”. Not only is this daft [...]

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Offshore Investing

Investing Offshore can be a very attractive option for the discerning investor who would like to explore other markets, shield his or her investments from potential capital lawsuits, or grow them in a confidential, secure investment not governed by the rules and regulations of their home jurisdiction. Over a year ago I posted an article [...]

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Vince Cable Visits Isle of Man Tax Haven

The Liberal Democrat Shadow Chancellor has been a stern critic of the Isle of Man, calling us a haven for tax dodgers. He also demanded that the Isle of Man be closed as a ‘tax haven’ and for banks receiving investment from the UK Government to shut offshore operations. Despite that he accepted an invitation [...]

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The Benefit of Offshore Trusts

For many years UK taxpayers benefitted greatly by transferring (settling) their assets in offshore trusts, but increasing ant-avoidance legislation has led people to believe that there is no point in using an offshore trust any more. Whilst it is true that the tax advantages are no longer as good and they once were the fact [...]

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UK Praises Isle of Man Stance on Tax Standards

There are stunned expressions on the faces of Isle of Man politicians, civil servants and business leaders who have just read an official press statement from Stephen Timms, Financial Secretary to the UK Treasury, seen here behind his political master Gordon Brown. After months, indeed years of undisguised hostility, most blatantly with Chancellor Alistair Darling’s [...]

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It is official: the Isle of Man is NOT a Tax Haven

As promised by Gordon Brown at the end of the G20 summit today, the OECD (Organisation for Economic Cooperation and Development) has provided a detailed report on progress by financial centres around the world towards implementation of an internationally agreed standard on exchange of information for tax purposes. The list is split into four sections [...]

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Offshore Tax Havens: Who Did Chancellor Merkel Have in Mind?

Anyone setting up a business in Germany has a few problems to overcome. High taxation, high social charges, and high cost of company formation to name just three. That’s why more and more Germans are setting up companies in the United Kingdom. Believe it or not, the UK remains very business friendly. Anyone can set [...]

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Isle of Man Praised by OECD Despite Attacks by UK Government

Whilst Gordon Brown, Alastair Darling and Barack Obama attack the Isle of Man as a “Tax Havens” the OECD (Organisation for Economic Cooperation & Development) praise the Isle of Man. If proof were ever needed that the bully boys of the UK and USA are attacking small offshore countries just to divert attention from their [...]

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Is the Isle of Man Really a Tax Haven?

I live in the Isle of Man. For those of you who don’t know this is a small island in the middle of the Irish Sea about midway between England, Scotland and Ireland (and a little further from Wales).   Although one of the British Isles we are an independent country – with the oldest [...]

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Withholding Tax Under Challenge

I recently received a question from the owner of a UK company questioning the imposition of Spanish withholding tax on payments his company received from a Spanish subsidiary. He thought that the EU Parent-Subsidiary Directive exempted the tax. In fact it would do for dividends but not for royalty payments, which these payments were for [...]

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The Remittance Basis of UK Taxation: What it Means for Persons Entitled to Claim Non Domicile Status

There has been much publicity and comment about “non doms” – these being persons who whilst resident in the UK are not domiciled there (see here for more information on what this means). The popular belief is that these people are unfairly avoiding tax on income or capital gains made outside the UK by claiming [...]

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Warning: UK and Offshore Managed Service Companies Under Attack

HMRC (Her Majesty’s Revenue & Customs) have announced that they are gearing up to mount an attack on Managed Service Companies (MSCs) based in the UK and offshore. Background For many years now HMRC has battled to try and stop what it perceives to be the unacceptable use of limited companies as a way for [...]

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Contractors Warned Over Offshore Solutions

Recent UK legislation has resulted in the real possibility that contractors using offshore umbrella companies could face massive back tax bills. For a number of years now many contractors have worked via umbrellas companies based offshore in jurisdictions such as the Isle of Man. These companies have offered contractors up to 85 per cent of [...]

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Too Little Too Late? – Australian Tax Review Consultation Paper Published

Ken Henry, Australia’s Treasury Secretary today unveiled the first in a series of long awaited consultation papers which are aimed at simplifying the country’s overcomplicated tax system in a bid to attract greater investment into the country. Currently Australians are subject to 125 different taxes, but the vast majority of government revenue (about 90%) is [...]

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Domicile – Having Your Cake and Eating It

International businessman Robert Gaines-Cooper has failed to persuade the Court of Appeal that he has changed his UK domicile. We read a lot in the UK press about “non-doms” and how they don’t pay their fair share of tax. Recent legislation has made it more difficult for “non doms” to benefit but as usual the [...]

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