Monthly Archives: November 2020

A United Kingdom Limited Liability Partnership (LLP) is a very popular vehicle for international commercial activity.  This is because the UK LLP is a body corporate with a legal personality that provides its members with limited liability, and at the same time, it’s tax transparent.

The law states that a trade, profession or business conducted by a UK LLP shall be treated as though carried out in partnership by its members.  The effect of this is to ensure that members of an/the LLP are taxed as though they are partners in a partnership.

Reduced Taxation Opportunities for International Business 

The UK only taxes non-residents of the UK on their UK source income.  Therefore, when a UK LLP is engaged in a trade, profession or business, with a view to making a profit, and has no UK members or UK trade, no permanent establishment or UK source income, the UK has no authority to tax the LLP or its members. (The members and the shareholders of the members may potentially have a tax liability in their home jurisdictions).

Opportunities are therefore optimised where UK LLPs are formed to carry out non UK business by companies in zero or low tax jurisdictions.

Can a UK LLP Benefit from the UK’s Double Tax Treaties and Obtain a Tax Residence Certificate? 

As a UK LLP is not taxable, it cannot obtain a tax residence certificate.  In addition, as a UK LLP is not subject to tax on its profits, it cannot enjoy the benefit of the UK’s network of double tax treaties.

The relevant jurisdiction to obtain a tax residence certificate and for the application of double tax treaties, is the country of residence of the LLP members.

Can a UK LLP register for VAT in the UK? 

In theory as a UK LLP is considered to be a body corporate for VAT purposes, it should be possible to register an LLP for VAT, even if the LLP is not trading in the UK.

In practice however, a UK LLP without a UK trade, UK place of business or UK members will probably find it difficult to register for VAT in the UK.

Can a UK LLP which has no UK Members, UK Trade or Source Income have a UK Virtual Office? 

A UK address and telephone answering service are not on their own sufficient to create a permanent establishment in the UK.

If all activities are undertaken outside the UK, having a UK virtual office should not cause non-UK members of a UK LLP without a UK trade or source income to have a UK tax liability on the profits of such an LLP.

Who has the Powers of Management of an LLP ?

The powers of management rest with the members of an LLP.  It is sensible to have a members’ agreement which sets out the authority of the members to bind the LLP.

Where a member’s authority is limited, if the member acts broadly within the ambit of the LLP’s business, his acts are likely to bind the LLP. This is the case even if the member was acting outside of his authority, as defined in the members’ agreement, provided that the party with which the member is dealing does not know of such limitations to the powers of the member.

Do UK LLPs have to be Audited? 

The members of a LLP are obliged to prepare a balance sheet and profit and loss account for each financial year of the LLP.  These accounts, together with a copy of the Auditor’s report (where applicable) must be delivered to the Registrar of Companies.  The accounts will then be in the public domain and are open to inspection.

LLPs that are regarded as small are exempt from an audit requirement.  To qualify as a small LLP the LLP must have gross assets of not more than £3.26 million, and its turnover must not exceed £6.5 million.  In addition, the LLP must not be part of a group where a public company is a member, or where the group is not defined as small.

It should be noted that even where an audit is not required, members are still required to prepare and file true and fair accounts.

Is there a Minimum Capital Requirement? 

There is no minimum capital requirement for the formation of an LLP.  An LLP must, however, have at least two members.  The members may be corporate bodies and may be incorporated and resident anywhere in the world.

Are there any Activities for which an LLP should not be Used? 

An LLP is tax transparent if it is engaged in a trade, profession, or business with a view to making a profit.  An LLP is therefore not tax transparent for clubs, charities or similar organisations. 

There is some anti-avoidance legislation and, in particular, if a pension fund is a member of a LLP which invests in property, that LLP will not be tax transparent.

UK resident members of an investment LLP will not be able to offset interest charges against income they receive from such an LLP when calculating their taxable income.  This does not however affect non-UK members of an investment LLP that has no UK source income.

Summary

LLPs are becoming increasingly popular. This is largely due to the fact that no personal liability falls on a member of an LLP for contracts or debts of the LLP and there is no joint or several liability for the negligence of any other member.

If correctly structured, international business operated by UK non resident members will not be subject to UK taxation, but will, nevertheless, present a UK presence to the outside world. 

NOTE: OCI are not legal or tax or financial advisers. Local laws can have an impact. Hence you should seek local legal, taxation and financial advice before committing to establish a structure such as that described above. 

Would you like to know more? Then please Contact Us:

www.offshoreincorporate.com

info@offshorecompaniesinternational.com

ocil@protonmail.com

oci@tutanota.com

oci@safe-mail.net

ociceo@hushmail.com

Limited Liability Partnerships (LLPs) were introduced by the LLP Act 2000 and were the first new UK legal entity for nearly 100 years. They were intended for use by the larger professional practices but have already been utilized by a wide variety of businesses.

Tax Transparency

LLPs are not liable to income tax, corporation tax or capital gains tax on their profits and gains. Instead, the members of the LLP will each be taxed on their share of the profits or capital gains (including profits retained in the LLP). Thus the LLP business itself is “tax transparent”.

Body Corporate

Although an LLP will be taxed as though it is a partnership, it is in law a “body corporate” with a separate legal personality from that of its members. This means that, unlike a conventional partnership, an LLP can enter into contracts and hold property in its own right. LLPs will also be able to continue in existence independent of changes in membership. Additionally, there is no need for a small number of members to act as nominees for all of their fellow members and the firm. LLPs need to be registered at Companies House in the same way as limited companies. They will receive a registration number and will be obliged to file annual accounts. Subject to exemptions for dormant LLPs and small LLPs, the accounts must be audited on a “true and fair” basis, in just the same way as limited companies.

Limited Liability

As the name suggests, LLPs offer “limited liability” to all of their members. This is the same as applies to shareholders of a limited liability company. It means that (subject to two exceptions – see “Unlimited liability” below) on the insolvency of an LLP, each member’s liability extends only to the amount that the individual has contributed to the LLP by way of capital. In the same way as the liability of a shareholder in a limited company extends only to the amount he or she has contributed by way of share capital. Thus creditors have no recourse to members’ personal assets. Also, as in a limited company, persons who have made loans to LLPs will be treated as general creditors unless the loans were secured. Provided it is the LLP that enters into contracts with third parties, it will be the LLP that is generally liable for all debts, obligations, wrongful acts and omissions. The funds available to meet such liabilities will be limited to those within the LLP.

Unlimited Liability

For LLPs there are two important exceptions to the basic concept of limited liability:

• If a member has accepted a personal duty of care to a third party and has acted in breach of that duty of care then the member will be personally liable. Similarly, if a member has accepted a personal contractual commitment and has acted in breach of that commitment, they will be personally liable to an action in tort in connection with the negligent work, etc. This position is no different from directors of a limited company who can become personally liable if they accept personal duties or commitments;
• Members might also have additional liabilities in the event of an LLP becoming insolvent if the “clawback” rules are in point.

Withdrawals

All payments made by the LLP to members, by way of drawings, profit shares, repayment of capital and repayment of loans, constitute withdrawals of money by members from the LLP.

Clawback

This term refers to the possibility that if an LLP becomes insolvent, then any “withdrawals” from the firm by any member in the previous two years are potentially vulnerable to a claim that they should be repaid. However, such a claim will only succeed if it can be shown that the member in question either:

• knew that there was no reasonable prospect of avoiding insolvent liquidation at the time of the withdrawal; or
• should have known, or ought to have concluded, that there was no reasonable prospect for avoiding insolvent liquidation.

Incorporation

LLPs will be “incorporated” and registered at Companies House by following a procedure similar to that for limited companies.

Members’ Agreement

LLPs will normally be governed internally by a formal agreement between the members. There is no legal obligation on the members of an LLP to approve a “Members’ Agreement”.

The written Members’ Agreement can provide virtually anything that the members want it to in relation to how the LLP will be managed, how decisions relating to the LLP will be taken, how profits will be distributed and how capital will be contributed. As the LLP is a body corporate with a separate legal personality from its members, the agreement should also define the duties owed by members to the LLP, by the LLP to the members, and by the members to each other.

The Members’ Agreement will be a private document between the members and need not be filed at Companies House.

If the members of an LLP do not have an agreement between them as to how the LLP shall be operated, various default provisions apply under the LLP Act. However, these are extremely brief and unsatisfactory. For example, they provide that members will share profits equally irrespective of capital contributions to the LLP and that no member may be expelled for any reason.

Anti-avoidance Provisions

The Government is keen to prevent any potential tax loss through the use of investment and property investment LLPs. The main thrust of the provisions relating to LLPs, is to discourage tax exempt vehicles and funds from using LLPs for property investment activities.

Taxation Overview

LLPs are in law regarded as “bodies corporate” and will be subject to aspects of company law. But for tax purposes they will generally have the same tax transparency as conventional partnerships.

The LLP Act 2000, introduced various changes to the Taxes Acts. These changes were intended to ensure that where an LLP carries on a “business with a view to profit” then its members will be treated for the purposes of income tax, corporation tax and capital gains tax as if they were partners carrying on business in partnerships. That is to say, the LLP will be regarded as transparent for tax purposes and each member will be assessed on their share of the LLPs income or gains.

International Issues

Because an LLP is a “body corporate” an overseas branch of an LLP may well be taxed as a corporate entity in certain overseas countries. The Inland Revenue has confirmed that it will be for the relevant overseas tax authority to determine how the LLP and its members are to be taxed locally. However, the Inland Revenue has confirmed that it will be prepared to allow UK-based members to claim a double tax credit for their proportionate share of overseas corporate tax paid, when computing their UK income tax liability on the same income.

For UK tax purposes, dividends received by an LLP will be deemed to have been received directly by its members. This means that where foreign dividend income arises it will be the individual members that need to consider the relevant double tax agreements. Thus it will normally be the withholding tax limits applicable to individual members that will apply, such that there will be no relief (as there is for companies) for locally paid underlying corporate taxes.

The position will be similarly complicated for non-UK resident members of an LLP if the members’ country of residence considers the LLP to be a corporate body for local corporate taxes. In such cases it may regard profit distributions made to the members as dividend distributions and deny tax credit relief for any taxes paid by them in the UK (where the LLP is carrying on its trade or profession). Such income tax may be considered to have been payable by the LLP and thus a form of underlying tax, in respect of which the members are not entitled to claim credit overseas.

A UK LLP can be incorporated with wholly non-resident members and unless that LLP trades, or holds investments in the UK, its members should have no UK liability on their share of the LLPs profits. However, that could mean that the LLP would have no UK taxable presence and thus its commonly recommended that every LLP has at least one UK resident member, paying tax on its share of profits in the UK.

Cessation of LLP

Where an LLP comprises of only two members and one of them dies, for example, another member will need to be appointed within six months, or the LLP will be dissolved with the tax consequences following as set out below.

Technically, whenever an LLP ceases to carry on a trade or profession it will no longer be regarded as a “partnership” for tax purposes. Instead it will cease to be transparent and should become liable to corporation tax.

Strictly, corporation tax would be due on gains made at the LLP level after it ceases to trade, with capital gains tax being due on gains members’ make when they “realise” their interests on liquidation. This is the same as the double taxation which arises where valuable assets are held within a corporate structure.

However, where members wind-up the LLPs affairs informally without undue delay and where tax avoidance is not a motive, the Inland Revenue will treat the LLP as remaining tax transparent. Thus, where there is a gradual disposal of assets and settlement of debts with the liquidator appointed only for the final formalities, the prospective double taxation can be avoided.

However, once a liquidator is appointed, chargeable gains on the disposal of any of the LLPs assets by the liquidator will be computed by reference to the date on which they were first acquired by the LLP and their cost at that date. In the liquidation period, the LLPs capital gains would be treated in precisely the same way for tax purposes as those for any other body corporate. Similarly, members of the LLP will be taxed on any gain (or given relief for any loss) that arises on the disposal of their capital interests in the LLP.

The base cost of members’ capital interest will not be set by reference to the market value of that interest at the time when transparency is lost. Instead the allowable acquisition of each members’ interest will be determined according to the historical capital contributions made, as if the LLP had never been transparent.

Summary

If you’re considering incorporating anil tax  Company Offshore but don’t want the stigma that can sometimes be attached to the use of classical Tax Haven Companies (eg BVI, Seychelles, Belize etc IBCs) then the UK model of LLP is an entity well worthy of close consideration.

OCI can set up a UK LLP for as little as $800 (and Nominee Members/Partners can also be supplied).

Warning: OCI are not tax advisers or legal advisers. Local laws can have an impact. Hence you should seek local legal/tax/financial advice before committing to set up a UK LLP.

Would you like to know more? Then please Contact Us:

www.offshoreincorporate.com

info@offshorecompaniesinternational.com

ocil@protonmail.com

oci@tutanota.com

oci@safe-mail.net

ociceo@hushmail.com

This week we continue our examination of the options available to you if you’re looking to establish residency or a residential address outside of your usual country of abode.

A quick recap…

So why might somebody wish to have a second residence?

There are a number of valid reasons as to why someone would want to secure residency entitlements in a second country including:

• As insurance against political, economic or social upheaval in the person’s historical home country
• To make international travel simpler (eg Depending on where you are from if you hold a passport that is considered “problematic” by the country you intend to visit entry VISAs, even for holiday visits, can be very hard to come by)
• As a vehicle to enable you to avoid being discriminated against (ie by virtue of your country of origin)
• To enhance employment prospects outside of your home country
• To avoid the risk of potentially hostile treatment by Government officials, kidnappers and hostage takers
• To access new opportunities for the tax structuring of one’s personal or corporate tax affairs. (Generally, an individual’s residence and citizenship are the ultimate basis for the majority of taxation rulings)
• For enhanced privacy – Modern day information sharing protocols make it possible for your local authorities to be automatically informed by “reporting entities” (ie banks, asset managers etc) if you hold certain assets outside of your home county. In such instances information is usually only shared with the country which appears as your home state in the proof of address document you provide to your non local Bank/Asset Manager
• Citizens of certain countries are subject to tax on their worldwide income, regardless of where they may be residing. By relinquishing one’s current passport/citizenship and taking up a new one such persons might be able to take advantage of residence-linked tax planning opportunities that would otherwise be beyond access.

Panama has one of the strongest histories in terms of offering second residency programs. For some time it has offered what is known as The Panama Pensionado Visa which allows foreigners to obtain legal residency in Panama under the condition that they have a pension income (of minimum $1,000 per month) guaranteed for life.

A recent addition to its offerings is the Friendly Nations Visa.

With the Panama Friendly Nations Visa there is nothing to invest midterm or long term, you just need to:

(a) create a company in Panama where you will be the President and Shareholder and claim that it will be used for professional services in Panama; and

(b) open a bank account in your name. (This bank account would have to be funded with a minimum of $5,000.00. If there are dependents that will apply with the main applicant, then $2,000.00 per dependent needs to be added).

Most of the bank account opening process can be done without you needing to visit Panama, so we can advance 90% with that and, once you arrive in Panama, finalize everything so that the account is opened in approximately 2 weeks.

You will need to travel to Panama at least twice.

On the first trip you will need to meet the bank and finalize the account opening, sign the power of attorney empowering us for the purpose of filing the application and have your passport registered with the Immigration Service.

Once the bank account is open you will need to send funds to activate the account and request the bank for a letter of reference and/or a statement of account stamped by the bank and then start the process of incorporation of the company (takes roughly 5 days to incorporate a company). The account would need to be funded with $5,000.00 and $2,000.00 extra per dependent if such is the case.

If you’re able to stay in Panama for this whole time, we can file the application right away and obtain the provisional residence permit and multiple entry and exit permit (this last one is necessary to leave the country while the visa is being processed as otherwise upon the return of you can be penalized with a fine of $2,000.00).

On the second trip, ie once the Visa is approved, you will need to travel to Panama to get your permanent resident card.

Our legal fees are $7,000.00 for the main applicant, plus $1,000.00 per dependent. The fee includes the company formation.

The approximate expenses are:

• $1,690.00 for main applicant and $1,300.00 per dependent. (Children under 12 years of age are exempt of the repatriation deposit of $800.00);
• Our legal fees for the attainment of the Multiple Entry and Exit Permit is $500.00 (per applicant) + $200.00 (per applicant) in costs payable to the Immigration Service.

To open the account, you will need to travel to Panama and meet the bank, plus bring with you the following documents:

- Reference letter from a bank

- Reference letter from a lawyer, accountant or other professional

- Reference letter from a business partner

- Copy of your entire passport (the bank will make a copy)

- Copy of a secondary ID such as a driver’s license

- Proof of income, which can be provided in the form of payment stub from your current employment or by submitting the last three tax returns you have filed.

These documents can all be submitted in English.

For the Visa, it is imperative that you have the bank account, so after the bank account is opened we can move forward with the Visa. 

The documents each applicant needs to bring with him/her for the Visa are:

- Valid passport

- Police record issued by the FBI, RCMP or equivalent authority in your country (except children under 18)

- Marriage certificate (applicable if legally married and spouse is applying as dependent of main

applicant)

- Birth certificate (applicable if children of the applicant under 18 years of age are applying as dependents of the main applicant).

The rest of the documents can be obtained in Panama, including the Declaration form of personal background information.

Any and all documents issued abroad have to be legalized by means of a Panama Consulate or via Apostille and duly translated to Spanish.

Translations prepared abroad would also have to comply with the legalization via Consulate or be Apostilled.

Would you like to know more? Then please Contact Us:

www.offshoreincorporate.com

info@offshorecompaniesinternational.com

ocil@protonmail.com

oci@tutanota.com

oci@safe-mail.net

ociceo@hushmail.com

Last week we began looking at reasons why people obtain, and various ways that one might apply for, a “Second Residence” outside of one’s normal place of abode, beginning with the Nevis Citizenship Program.

This week’s feature article looks at how one might go about obtaining the right to reside permanently (ie obtain a second residence VISA) in the United Arab Emirates (“UAE).

There are two options whereby an Entrepreneur or Investor can obtain residency rights in the UAE:

• By setting up a (particular kind of) company
• By purchase of real estate

We can offer you a number of free zones where you could register company in UAE. The most popular options is to register a Company in the Umm Al Quwain FZ.

Company registration in UAQ FZ with Flexi Desk (including 2 Visas)

Re the business activities of the company, you can simply choose from the below list (as updated from time to time by the Registrar of Commercial and Consultancy Activities) and following incorporation of the Company 2 Residency VISAs can be obtained:

1. COMMERCIAL LICENSE (TRADING LICENSE)

There are two types of license, which fall under this category: Commercial License and General Trading License.

Commercial License: This authorizes the import, export, distribution and storing of items specified on the license. A Commercial License can have three different product lines or 10 similar product lines.

General Trading License: This enables the licensee to trade in a wider range of activities and gives the freedom and flexibility to trade in any commodity, which is permitted within the UAE.
Note: Commodities which require special approval or clearance from various UAE authorities e.g. explosives and armaments cannot be traded with a General Trading license.

Usual activities include i.e. Trading with Automobiles, Seeds Trading, Coal & firewood trading, cotton and natural fibers trading, etc.

2. CONSULTANCY LICENSE

This is for entities, which offer expert or professional advice, and is issued to all manner of professionals including artisans and craftsmen. It allows two similar activities.

Activities usually registered include Marketing Consultancy, Management Consultancy and IT Consultancy.

3. FREELANCE PERMIT

This allows an individual to operate as a freelance professional, and conduct business in one’s birth name as opposed to a brand name or company. The Freelance Permit is designed for individuals who operate in technology, media and film sectors, and is issued to talent roles, creative roles and selected administrative roles.

Activities usually registered include Actors, Artists, Photographer and Producer.

4. INDUSTRIAL LICENSE

This enables the licensee to import raw materials, then manufacture/ process / assemble / package the specified products, and export the finished product. It allows the holder to import raw materials for the purpose of manufacturing, processing and/or assembly of specified products.

5. SERVICE LICENSE

This license is for service providers. It permits the licensee to carry out the services specified on the license within the Free Zone, such as Logistics; Courier Services; Insurance Service Provider; Travel Agency; Tour Services; Car Rental etc.

Tax Residency

An Umm Al Quwain FZ Company can issue residence permits and obtain a tax residence certificate from the UAE authorities for its foreign owners and executives. A FZ company, must have physical presence in the UAE and, in that respect, it must own or hire premises.

Private accommodation is not necessary for Umm Al Quwain Free Trade Zone Authority when applying for residence but many do this to reinforce their case for substance and legitimacy.

As far as the company is concerned, it must have physical presence in the UAE. In that regard, cost effective options are proposed by free zones situated in a number of emirates including Umm Al Quwain Free Trade Zone (UAQ FTZ). Usually, these options consist of “flexi desks” or “flexi offices”. (The below quote assumes the Company will uptake the Flexi Desk option).

Furthermore (if a local bank account is maintained with movements), the foreign owners and executives can apply to the UAE Ministry of Finance to receive UAE tax residence certificates.

A UAE residence permit and a tax residence certificate can be useful to foreign owners and executives who wish to register their tax residency in the UAE. It is worth noting, that banking institutions in UAE and many outside consider UAE tax residence certificates as sufficient proof of tax residency in the UAE.

To obtain such a permit would costs circa (including bank ac setup) $US11,000 and from 2^nd year circa $6,500.

Residency via the purchase of UAE real estate

• In this case a residence VISA of 3 years minimum duration can be obtained via the purchase of real estate in Dubai or other Emirates in the UAE
• The cost of real estate property in order to be able to obtain a resident visa must be – from 1 million dirhams (AED) per person or family. This means that if a house is bought by a husband and wife, then the cost must be at least 1 million dirhams. If the buyers are people who are not connected by family ties, then – 1 million dirhams (AED) for each person in one facility or for each separate facility worth at least 1 million AED.
• Buyer’s age can be up to 60 years. If you are over 60 years old, then you will need to obtain special approval allowing you to obtain a resident visa.
• Accommodation must be located in a completed building. Buying real estate property in Dubai during the construction period (ie “off the plan” projects) does not give one the right to obtain a residency permit in the UAE until the completion of construction work and the commissioning of the project.
• After purchasing real estate property and obtaining a resident visa, the owner can provide property for rent.
• The property can only be a Residential property. Purchase of a commercial property does NOT entitle the Investor does to obtain a UAE resident visa.
• Resident visa, obtained upon the purchase of an apartment, is issued for 3 years with the possibility of extension.
• To obtain a resident visa, the property owner must prove a monthly income average amount of min USD 2,860.
• The cost of obtaining 1 resident visa at the Immigration Department of the Dubai Land Department for an investor is: from USD 6,300.

Would you like to know more? Then please Contact Us:

www.offshoreincorporate.com

info@offshorecompaniesinternational.com

ocil@protonmail.com

oci@tutanota.com

oci@safe-mail.net

ociceo@hushmail.com

Given the inherent limitations that a single residency/passport can have on one’s lifestyle, freedom and financial future savvy investors, retirees and entrepreneurs the world over are becoming ever more aware of the potential rewards that holding a second passport/residency can deliver.

There are an ever-expanding number of jurisdictions now offering a second residency/passport options. Each of those will be canvassed over the course of the coming weeks in this Blog site. The purpose of this Article today meanwhile is to examine the second residency/passport options currently on offer from the picturesque Caribbean (dual) island Federation of St Kitts & Nevis.

Saint Kitts and Nevis – Overview

Saint Kitts and Nevis (officially known as the Federation of Saint Christopher and Nevis or “SKN”) is an island country in the West Indies. Located in the Leeward Islands chain of the Lesser Antilles, it is the smallest sovereign state in the Western Hemisphere, in both area and population. The country is a Commonwealth realm, with Elizabeth II as Queen and head of state (it gained its independence from Great Britain in 1983) and is the only federation in the Caribbean. SKN boasts a high degree of political stability, stunning natural scenery/beaches and an enviable tropical climate; Its primary economic pillars include Tourism (mainly Cruise ship visits) Agriculture, Commercial Fishing and Financial Services.

St. Kitts & Nevis permits foreigners to obtain the status of a St. Kitts & Nevis citizen by means of a government sponsored Citizenship-by-Investment program. Established in 1984 following decades of stagnant to negative population growth (many young people move to the bigger islands or the US upon finishing school), the St. Kitts’ citizenship program is the oldest remaining economic citizenship program of its type in the world. Notwithstanding its age, the program began to truly rise in prominence from around 2006 when the program was restructured to allow donations to the country’s sugar industry as the basis for residency/citizenship entitlements.

Further amendments to the program in 2020, post Covid (see below) have seen the Nevis citizenship by investment rise substantially in prominence.

Advantages of Holding a Second Passport?

There are a number of valid reasons as to why someone would want to secure residency entitlements in a second country including:

• As insurance against political, economic or social upheaval in the person’s historical home country
• To make international travel simpler (eg Depending on where you are from if you hold a passport that is considered “problematic” by the country you intend to visit entry VISAs, even for holiday visits, can be very hard to come by)
• As a vehicle to enable you to avoid being discriminated against (ie by virtue of your country of origin)
• To enhance employment prospects outside of your home country
• To avoid the risk of potentially hostile treatment by Government officials, kidnappers and hostage takers
• To access new opportunities for the tax structuring of one’s personal or corporate tax affairs. Generally, an individual’s residence and citizenship are the ultimate basis for the majority of taxation rulings
• For enhanced privacy – Modern day information sharing protocols make it possible for your local authorities to be automatically informed by “reporting entities” (ie banks, asset managers etc) if you hold certain assets outside of your home county. (In such instances information is usually only shared with the country which appears as your home state as noted in the proof of address document as provided by you to your non local Bank/Asset Manager)
• Citizens of certain countries are subject to tax on their worldwide income, regardless of where they may be residing. By relinquishing one’s current passport/citizenship and taking up a new one such persons might be able to take advantage of residence-linked tax planning opportunities that would otherwise be beyond access.

What Does a St Kitts & Nevis Passport Offer?

• Applicants do not need to travel to St Kitts & Nevis for the application and there are no annual residency rules to maintain the passport.
• A single application can include children up to a maximum age of 30 and parents with a minimum age of 55.
• New fast track processing enables receipt of a St Kitts & Nevis passport in 45 days (usual time is 3-4 months).
• Passport holders enjoy full Schengen privileges and can travel to approximately 120 countries worldwide, either on a visa free, or visa on entry basis. A visa is not required to visit the UK.
• If holders of the passport choose to move to St Kitts & Nevis there is no personal income tax, no gift tax, no death duties, no estate tax, no inheritance tax and no capital gains tax on worldwide income.
• The passport allows the holder to reside in other Caribbean Community countries (Caricom) if they wish to do so. There are 15 Caricom member states.

St Kitts & Nevis Citizenship by Investment Options

Currently there are three investment routes available for persons looking to take out SK&N Citizenship:

1. Contribution to the sustainable growth fund
2. Approved property development
3. Luxury Real Estate Purchase

Sustainable Growth Fund (SGF) Contribution

• A single applicant must make a contribution of US$150,000 to the Sustainable Growth Fund (SGF).
• For families looking to obtain SK&N Citizenship (usually, see below), the contribution for a family (of up to 4 persons) is US$195,000.
• For additional dependants (ie over 4), regardless of age, the contribution requirement is US$10,000 per dependant.

NEWS FLASH: The St Kitts & Nevis Government have announced, for applications lodges between 1 July 2020 and 15 January 2021, that the citizenship contribution for a family of four has been reduced from US$195,000 to US$150,000 per family.

Approved Property Development

In this category the applicant must invest a minimum US$400,000 in an approved property development. AND the property must be held for a minimum of 5 years after citizenship has been granted.

A registration fee is payable by the applicant and additional fees are required for the spouse, children under the age of 18 and additional family members over the age of 18.

If this route is selected, OCI can help source management services for the property, which can be sold on after 5 years.

NEWS FLASH: The St Kitts & Nevis Government have announced, for such purchases made between 1 July 2020 and 15 January 2021, that stamp duty has been reduced from 10% to 2.5%.

A registration fee is payable by the applicant and additional fees are required for the spouse, children under the age of 18 and additional family members over the age of 18.

Luxury Real Estate Purchase

With this category citizenship can be obtained if you invest a minimum US$200,000 in new luxury real estate. AND The property must be held for a minimum of 7 years after citizenship has been granted.

NEWS FLASH: The St Kitts & Nevis Government have announced that between 1 July 2020 and 15 January 2021, stamp duty for such purchases has been reduced from 10% to 2.5%.

A registration fee is payable by the applicant and additional fees are required for the spouse, children under the age of 18 and any additional family members over the age of 18.

Dependants & Citizenship by Descent

Dependants outside of the normal parent child gamut are also catered for:

• Unmarried, dependant children who are older than 18 but younger than 30 may be included in your Citizenship application.
• If you have dependant parents aged 55 or above they may also be included.
• Citizenships so obtained can be passed on to future generations by descent.

Fast Tracking

As regards any/all of the above 3 SK&N Economic Citizenship routes the application process will take 3-4 months. BUT If you’re willing and able to pay an additional US$46,000, however, your application can be fast-tracked, meaning your passport will issued in approximately 45 days’ time.

Would you like to know more? Then please Contact Us:

www.offshoreincorporate.com

info@offshorecompaniesinternational.com

ocil@protonmail.com

oci@tutanota.com

oci@safe-mail.net

ociceo@hushmail.com