High-Tax Jurisdictions
Preface
Australia
Transactions with Low-Tax Jurisdictions
Tax Treaty Regime
Treatment of Offshore Transactions
Devices for Utilising Low-Tax Jurisdictions
Austria
Attitude of Fiscal Authorities
Tax Treaty Regime
Treatment of Offshore Transactions
Devices for Utilising Low-Tax Jurisdictions
Belgium
Transactions with Low-Tax Jurisdictions
Absence of General Anti-Avoidance Disposition
Anti-Avoidance Dispositions of the Income Tax Code
Tax Treaties
Treaty Shopping
Vehicles for Using Low-Tax Jurisdictions
Canada
Transactions with Low-Tax Jurisdictions
Tax Treaty Regime
Treatment of Offshore Transactions
Permissible Devices for Using Low-Tax Jurisdictions
Conclusion
Finland
Introduction
Tax Treaty Regime
Treatment of Offshore Transactions
France
Introduction
Low-Tax Jurisdictions
Tax Treaty Regime
Treaty Shopping
Tax Haven Legislation
Tax Vehicles
Germany
Transactions with Low-Tax Jurisdictions
Tax Treaty Regime
Treatment of Offshore Transactions
Permissible Devices for Utilising Low-Tax Jurisdictions
Greece
Introduction
Attitude of Fiscal Authorities towards Transactions
with Low-Tax Jurisdictions
Tax Treaty Regime
Treatment of Offshore Transactions
Permissible Devices for Utilising Low-Tax Jurisdictions
Indonesia
Tax Regime
Double-Taxation Treaties
Indonesian Source Jurisdiction
Residence Jurisdiction
Italy
Transactions with Low-Tax Jurisdictions
Tax Treaty Regime
Treatment of Offshore Transactions
Use of Tax Havens
Japan
Introduction
Tax Treaty Regime
Domestic Legislation with Regard to Low-Tax Transactions
Transfer Pricing
Mexico
Attitude of Fiscal Authorities toward Transactions
Involving Low-Tax Jurisdictions
Tax Treaty Regime
Treatment of Off-shore Transactions
Permissible Devices for Utilising Low-Tax Jurisdictions
The Netherlands
Transactions with Low-Tax Jurisdictions
Tax Treaty Regime
Treatment of Offshore Transactions
Permissible Devices for Utilising Low-Tax Jurisdictions
New Zealand
Introduction
Tax Treaty Regime
Treatment of Offshore Transactions
Permissible Devices for Utilising Low-Tax Jurisdictions
Norway
Transactions with Low-Tax Jurisdictions
Tax Treaty Regime
Treatment of Offshore Transactions
Permissible Devices for Using Low-Tax Jurisdictions
Portugal
Transactions with Low-Tax Jurisdictions
Permissible Devices for Utilising Low-Tax Jurisdictions
Romania
Introduction
Attitude of Fiscal Authorities towards Transactions
Involving Low-Tax Jurisdictions
Tax Treaty Regime
Spain
Transactions with Low-Tax Jurisdictions
Tax Treaty Regime
Treatment of Offshore Transactions
Devices for Using Low-Tax Jurisdictions
United Kingdom
Transactions with Low-Tax Jurisdictions
Tax Treaty Regime
Offshore Transactions
Devices for Utilising Low-Tax Jurisdictions
United States
Transactions with Low-Tax Jurisdictions
United States Patriot Act
Tax Treaty Regime
Treatment of Offshore Transactions
Permissible Devices for Utilising Low-Tax Jurisdictions
Low-Tax Jurisdictions
Anguilla
Introduction
Tax Regime
Impact of Tax Treaties
Sourcing Income within Anguilla
Establishing Residence within Anguilla
Vehicles Available for Achieving Favourable Tax Status
Aruba
Introduction
Aruba Tax Regime
Advantages of Sourcing Income in Aruba
Vehicles for Achieving Favourable Tax Status
Impact of Tax Treaties and Kingdom Tax Arrangement
Establishing Residence and Presence in Aruba
The Bahamas
Introduction
Individuals
Companies
Partnerships
Trusts
Taxes
Special Business
Barbados
Introduction
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Procedure for and Advantages of Sourcing Income
Procedure for and Advantages of Establishing Residence
Belize
Introduction
Tax Tools
Banking
Tax Regime and Classification as No-Tax Jurisdiction for Non-Residents
Establishing Residence in Belize
Domestic Taxes for Residents
Vehicles Available for Achieving Favourable Tax Status
Bermuda
Tax Regime
Impact of Tax Treaties
Sourcing Income within Bermuda
Establishing Residence within Bermuda
Vehicles Available for Achieving Favourable Tax Status
Conclusion
British Virgin Islands
Introduction
Definitions
Tax Regime and Classification as No Tax or Low Tax
Stamp Duty
Tax Treaties
Sourcing Income within the British Virgin Islands
Vehicles for Achieving Favourable Tax Status
Conclusion
Cayman Islands
Introduction
Banking
Insurance
Corporations and Companies
Limited Partnerships
Trusts
Residence, Employment, and Carrying on Business
Costa Rica
Tax Regime and Classification as Low-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income in Costa Rica
Establishing Residence in Costa Rica
Vehicles Available for Achieving Favourable Tax Status
Cyprus
Introduction
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income within Cyprus
Dominica
Introduction
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Procedure for and Advantages of Sourcing Income within Jurisdiction
Caribbean Common Market
Procedure for and Advantages of Establishing
Residence within Jurisdiction
Vehicles for Achieving Favourable Tax Status
Gibraltar - Reserved
Guernsey
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Tax Treaties
Procedure for and Advantages of Sourcing Income
within the Jurisdiction
Procedure for and Advantages of Establishing Residence
within the Jurisdiction
Vehicles Available for Achieving Favourable Tax Status
Hong Kong
Introduction
Tax Regime and Classification as a Low-Tax Jurisdiction
Impact of Tax Treaties
Profits Tax in Hong Kong
Establishing Residence within Hong Kong
Ireland
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income within Ireland
Establishing Residence within Ireland
Vehicles for Achieving Favourable Tax Status
Jamaica
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income in Jamaica
Establishing Residence in Jamaica
Vehicles for Achieving Favourable Tax Status
Jersey
Tax Regime and Status as Low-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income within Jersey
Establishing Residence within Jersey
Vehicles Available for Achieving Favourable Tax Status
Jordan
Introduction
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Non-Operating Foreign Companies
Investment Promotion
Jordan Industrial Estates Exemption
Free Zones
Aqaba Special Economic Area
Qualifying Industrial Zones
Estate Tax
Double Taxation Treaties
Kuwait
Status as Low-Tax or No-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income within Kuwait
Establishing Residence within Kuwait
Incentives
Liechtenstein
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Forms of Taxation
Impact of Tax Treaties
Sourcing Income within Liechtenstein
Establishing Residence within Liechtenstein
Vehicles Available for Achieving Favourable Tax Status
Conclusion
Macao
Introduction
The Tax System
Malta
Introduction
Sourcing Income within the Jurisdiction
Establishing Residence within the Jurisdiction
European Union, European Economic Area, and Swiss Nationals
Non-European Union, European Economic Area, and Swiss
Nationals
Double-Taxation Relief
Vehicles Available for Achieving Favourable Tax Status
Conclusion
Mauritius
Introduction
Tax Regime
Sourcing Income within Mauritius
Monaco
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Sourcing Income in Monaco
Establishing Residence in Monaco
Vehicles for Achieving Tax-Favourable Status
Conclusion
Netherlands Antilles
Classification of the Current Tax Regime and its Main Elements
Impact of Double-Tax Treaties
Procedure for and Advantages of Sourcing Income within the Jurisdiction
Procedure for and Advantages of Establishing Residence within
the Jurisdiction
Vehicles Available for Achieving Favourable Tax Status
Nevis
Introduction
Impact of Tax Treaties
Sourcing Income within the Jurisdiction
Establishing Residence within the Jurisdiction
Vehicles Available for Achieving Favourable Tax Status
Oman
Tax Regime
Procedure for Sourcing Income
Establishing Residence in Oman
Vehicles Available for Achieving Favourable Tax Status
Panama
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Establishing Residence within Panama
Vehicles Available for Achieving Favourable Tax Status
San Marino
Introduction
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income in San Marino
Establishing Residence in San Marino
Vehicles Available for Achieving Favourable Tax Status
Seychelles
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income in Seychelles
Establishing Residence within Seychelles
Vehicles Available for Achieving Favourable Tax Status
Singapore
Introduction
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income within the Jurisdiction
Establishing Residence within the Jurisdiction
Conclusion
Sri Lanka
Tax Regime and Classification as Non-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Procedure for and Advantages of Sourcing Income within Jurisdiction
Procedure for and Advantages of Establishing Residence within the Jurisdiction
Individuals
Vehicles Available for Achieving Favorable Tax Status
St Vincent and The Grenadines
Introduction
Tax Regime
Tax Treaties
Offshore Centre
Switzerland
Introduction
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income within Switzerland
Establishing Residence within Switzerland
Vehicles Available for Achieving Favourable Tax Status
Trinidad and Tobago
Introduction
Impact of Tax Treaties
Sourcing Income
Establishing Residence
Vehicles for Achieving Favourable Tax Status
Turks and Caicos Islands
Introduction
Tax Regime and Classification as No-Tax Jurisdiction
Impact of Tax Treaties
Procedure for and Advantages of Sourcing Income
Establishing Residence within the Jurisdiction
Vehicles Available for Favourable Tax Status
Conclusion
United Arab Emirates
Tax Regime and Classification as a No-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income in the United Arab Emirates
Establishing Residence in the United Arab Emirates
Vehicles Available for Achieving Favourable Tax Status
Uruguay
Offshore Corporations
United States Virgin Islands
Tax Regime and Classification as No-Tax or Low-Tax Jurisdiction
Impact of Tax Treaties
Sourcing Income in the United States Virgin Islands
Establishing Residence in the United States Virgin Islands
Vehicles Available for Achieving Favourable Tax Status
European Union
Introduction
Direct Taxes
Value-Added Taxes
Capital Duty
Transfer Pricing Convention
Mutual Assistance Directive
Case Law
Report on Harmful Tax Competition
Electronic Commerce
Double-Taxation Treaties
Introduction
Development of Double-Taxation Treaties
The Commentary
Types of Double-Taxation Agreements
Inheritance Tax Double-Taxation Agreements
Organisation for Economic Co-Operation Development Models
