Category Archives: Company- Management

Intellectual property (“IP”) is a creation of the mind and includes things like inventions, literary and artistic works, designs and symbols, software code, names and images used in business.

IP is commonly protected in law by way of patents, copyright and trademarks which enable the person who came up with the idea to securely earn recognition or financial benefit from whatever it is he/she has invented or created.

An Offshore IP company is an ideal vehicle for the administration and management of licenses and intellectual properties including computer software, technical know-how, patents, copyrights and trademarks.

Practicalities

So how does it work from a practical perspective?

At core the Offshore IP Company (which is usually set up in a nil or low tax country) is used to divert income from Trading Companies or Businesses trading in developed or high tax countries.

The first step is to transfer ownership of the IP rights to the Offshore Company/Entity.

Once that’s done the Trading Business then enters into a legal agreement (contract) with the IP Company whereby, in return for being allowed to use the IP, the Trading Company agrees to pay the Company royalties or license fees. The income arising from these agreements can then be accumulated offshore in a nil or low tax environment.

Timing is of critical importance – It is clearly preferable to acquire the IP (for example, a patent) at the earliest possible time (e.g. at the patent pending stage) before the IP becomes highly valuable. That way the capital payment for the acquisition of the IP (e.g. patent) can be set at a lower amount i.e. before its true worth has been determined in/by the market. (These capital payments may even be deferred and or staggered by way of an instalment contract such as would enable the IP Company to use subsequent royalty payments to fund the cost of the IP).
If a deal is struck for the Offshore IP Company to buy the IP before the IP gives rise to a product or service which is offered/advertised in the market the IP might even be transferred for nominal consideration enabling the IP inventor/creator to transfer patent, copyright or trademarks in favour of the low/nil tax company before the IP suffers significant appreciation in value.

Businesses Who Pay Royalties or License Fees for the use of IP

Once it has acquired the Property the Offshore IP Company can then issue (IP) sub-licenses or exploitation rights to appropriate third party structures.
For example, a majority of software companies license their users through companies which are established in “offshore” jurisdictions, or through a firm, which is not established in a classical offshore jurisdiction, but is owned or controlled by such a firm.

Typical examples of businesses that might pay license fees to a nil/low tax Offshore Company include:
- Software companies
- Companies doing business in information technologies
- License and copyrights to books, articles, music, films, etc.
- Users of Franchise operating systems

- Trademark product (e.g. Clothes/Consumer Goods/Accessories etc. Brand) manufacturers and or retailers

In some circumstances the royalties may be subject to withholding tax at source, however, the interposing of a second company in another jurisdiction may reduce the rate of tax withheld at source (a carefully selected jurisdiction can withhold taxes on royalty payments with the commercial application of double tax treaties).

Structuring Options

Another option, whilst you are still in the process of creating a new piece of intellectual property, is to involve or engage an offshore (nil tax) company as a foreign partner or financial sponsor. Participation in development at this early stage would entitle the Zero Tax Company to register as the owner or co-owner of the property.

If you involve an offshore company later, you have to sell or assign the title to the property to the offshore company, and these kind of transactions require at the least that a fair market price deal be apparent as if no associated parties were involved (+ the transfer may involve the incurring of some CGT on the part of the inventor/creator of the IP).

Benefits of an Offshore IP Company

There are numerous benefits that an IP holding company can deliver including:

• By placing your IP in one entity you are able to streamline the internal processes for inter-group licensing
• Cross-jurisdictional tax issues become simpler as you will be regularly licensing IP between the same jurisdictions
• You can justify staffing the Offshore IP Company with people who have the skills to manage the same so protecting valuable assets of the company further, simplifying the licensing process
• Assets can be valued due to the income stream that accrues for the benefit of the IP holding company
• The value of the shares in the entity can be included into the accounts which will benefit the shareholders of the holding company
• You can split your income streams in two enabling you to sell one chunk of your business first up (i.e. the operational business) whilst retaining the other (i.e. IP) arm of the business which would entitle you to receive passive income
• If your business or trading company ever gets sued and the IP is owned by a 2^nd (e.g. Offshore) Company the most precious asset of your business can/will not be lost.
• You get to retain ownership of your IP in a highly private environment where no one knows what you own or how much the IP is worth. (There have been many documented cases of inventors and artists who rise suddenly to fame only to lose their fortune just as quickly via a law suit filed by a disgruntled gold digging ex-lover or confidante… The chances of that happening if your IP is owned by a privacy haven company are GREATLY reduced)
• You can significantly if not dramatically reduce the tax that your operating/trading company would otherwise have to pay

Australia is being “picked off” by online foreign exchange brokers that are able to obtain a local licence and offer clients extremely high leverage of up to 500 times, Australia’s corporate watchdog the Australian Securities and Investments Commission (“ASIC”) says. 

Mr Greg Medcraft, chairman ofASIC, said the issue had been raised with the country’s top financial regulation forum, which comprises ASIC, the Reserve Bank, Treasury and the Australian Prudential Regulation Authority. 

“We’ve discussed this more globally, and we are being picked off as a jurisdiction that allows very high leverage, 500 to 1,” Mr Medcraft said at a parliamentary hearing on Friday. “We’re doing what we can in terms of vetting those who apply for licences in this area, particularly those that don’t have a [true] connection with Australia that are operating outside of Australia. 

“It is an issue that’s been discussed recently at the Council of Financial Regulators.”

Asked if participants in the foreign exchange market were sophisticated enough to understand the risk, ASIC Commissioner Cathie Armour said there was an “open issue”whether Australia should take the approach of other countries about limiting the amount of leverage.

CAPPED LEVERAGE

The US, Japan and Hong Kong have capped leverage. The watchdog has taken action against some Australian-based brokers. In October 2014, ASIC forced one of Australia’s foreign exchange brokers, Pepperstone, to exit the Japan market, after it was found not to have the appropriate licence. Pepperstone was offering clients leverage of up to 400 to 1, significantly above the regulatory maximum in Japan of 25 to 1.

Given the high leverage allowed in foreign exchange trading, ASIC’s Ms Armour said Australia was “quite fortunate” that brokers here had been able to operate effectively during the significant shock caused by the de-pegging of the Swiss franc in January.

High leverage creates the potential for greater profits, but also greater losses. January’s 30 per cent spike in the Swiss franc after its central bank dropped a peg with the Euro was one of the most dramatic moves ever in currency markets, and resulted in widespread losses for traders, brokers and investment banks.  

For a trader with 400 times leverage, the instant 30 per cent move resulted in a 1200 per cent loss, which exceeded the balance of most traders. FXCM, the world markets’ largest online foreign exchange broker, was forced into a distressed sale while British-based Apari declared insolvency.

The popularity of online foreign exchange trading has surged as technology has allowed individuals to bet on currency moves. Daily ­turnover has more than doubled from $136 billion to $380 billion since 2007 as speculators opt to trade foreign exchange markets that operate 24 hours a day. But foreign exchange markets are largely operated on the often opaque and unregulated over-the-counter basis.

Australia has become a hotbed of the global retail forex broking industry by virtue of its trading culture, and a safe jurisdiction for locally based players to market themselves to traders around the world. Such is its popularity that daily turnover at some of Australia’s largest brokers can exceed the entire cash equities volume of the Australian Stock Exchange on a given day.

THE SYDNEY MORNING HERALD

23 March 2015

Given we are now living in the Global Village, and as more opportunities exist now than even before for qualified professionals and trades/skilled persons to work as Consultants to (or to take up contracts offered by) non-local Companies, more and more clients are setting up (and hiring out their services via) a nil tax jurisdiction based Recruitment Agency or Labour Hire Company.

Here’s how it can work:

1. You would incorporate a new zero tax Offshore Company which might be called something like International Professional Recruitment Services Ltd  (hereinafter, “IPRS Ltd” or the “Employment Agent”)
2. This business would be characterized as, and appear to the outside world to be, a Professional Recruitment Agency or a (Specialist) Labour Hire Company
3. You might tell anyone who wants to hire you eg your existing employers (or contract counterparty if you are on a contract) that, as IPRS Ltd can offer you (a) consistent employment + (b) jobs the world over, and as they are experts in finding contracts for your Profession/Trade/Occupation, you are contracted exclusively to IPRS Ltd and anyone who wants to hire you has to sign an agreement with, and must pay, IPRS Ltd.
4. Your existing employers (or contract counterparty if you are on a contract), assuming they wish to keep you employed/engaged, would then have to sign a labour hire agreement with IPRS Ltd.
5. Your existing employers (or contract counterparty if you are on a contract) would thereafter pay your wages (or contract fees as applicable) to IPRS Ltd.
6. IPRS Ltd would keep a percentage of these payments as Agency commission (the commission could be anywhere from 2.5% to 50%).
7. The remainder of monies (ie after the tax free Offshore Company IPRS Ltd has retained its agency commission) would be paid to you by IPRS Ltd
8. The monies received by IPRS Ltd should be receipted free of tax and could be held and or invested Offshore potentially tax free.

For the above to work the agreement between your employers (and the agreement between you) and the Tax Haven Company IPRS Ltd would need to be (and be seen to be) commercially realistic.

Local laws can have an impact. Hence you would be wise to seek local legal and or tax advice before committing to create such a company/structure.

The Nevis Multiform Foundation Ordinance is a very unique and cutting-edge piece of legislation which was designed to remedy some of the problems seen in other foundation products.

The Nevis Multiform Foundations Ordinance provides that each Nevis Foundation will have a stated ‘multiform’. This means that the constitution of the foundation will state how it is to be treated whether as a trust, a company, a partnership or an ordinary foundation. Through the ‘multiform’ concept the stated identity of the Foundation can be changed during its lifetime, thus allowing for there to be greater flexibility in its use and application. Generally, the Nevis Multiform Foundation product can be used for estate planning, charity, financing and special investment holding arrangements.

There are five basic requirements for establishing a Nevis Multiform Foundation:

-       It must have a Nevis based registered agent (which OCI supplies)

-       It must have a Nevis registered office (which OCI supplies)

-       It must have an acceptable name

-       It must have a management board and secretary (which OCI can supply via Nominees); and

-       It must have a memorandum of establishment

Like the formation of a company, you must first engage the services of a registered agent who is authorized to act as agent of the entity, and that registered agent must have an office to which all communications and notices may be addressed. The Promoter of the Foundation, through its registered agent may reserve a name prior to establishment of the foundation. If the foundation is a trust foundation, then the name must accord with that multiform so that the trust foundation has the word “trust” in it. The name must not be prohibited by law: Irrespective of the prohibited word list the Registrar of Foundations will not reserve a name that is misleading, undesirable, confusing or similar to another name of an entity registered in Nevis.

Once the Registrar confirms that a name is available and valid for use, that name can be reserved for a period of one month. The Registrar has discretion to permit a name to be reserved for a longer period. Once a name has been reserved, the following establishment documents must be submitted to the Registrar in order to establish the Multiform Foundation:

-       Application Form

-       Consent Schedule

-       Memorandum of establishment

-       By laws (if standard by-laws are not adopted)

-       Evidence that the existing entity has been dissolved or discontinued or an undertaking that an application for dissolution or discontinuance has been submitted in the existing jurisdiction (where applicable)

The relevant fees must accompany the documentation for establishment of a Nevis Multiform Foundation.

The Nevis Multiform Foundation Ordinance also provides for entities to be converted or transformed, continued or consolidated and merged into a Nevis Multiform Foundation. Through the process of Continuance, a foundation in another jurisdiction can be continued in Nevis as Multiform Foundation.

Through the process of Transformation, any entity outside of Nevis can be transformed into a foundation in Nevis. Therefore, a trust in Jersey can become a multiform foundation in Nevis. Through the process of Conversion, an existing Nevis entity like an IBC can be converted to a multiform foundation.

Through the process of Consolidation or Merger, any two or more entities can merge into a multiform foundation and alternatively, through the process of Discontinuance, a multiform foundation can move to another jurisdiction. These provisions allow for the mobility of the foundations as an entity into and out of Nevis and give the founder an extremely valuable asset protection tool.

A new special economic zone (SEZ) has been confirmed in Qatar near the new Hamad Port, just south of Al Wakrah.

The zone, to be known as Um Al Houl Special Economic Zone, will seek to attract companies from the petrochemicals, building materials, maritime, metals, logistics, food processing, automobiles, tools, and machinery sectors.

The new zone, announced on March 2, is one of three SEZs being developed by Manateq, a company established by the Ministry of Business and Trade in 2011. Manateq intends to allow investors to develop land on the 33.52-square-kilometer site from the second quarter of 2016.

Manateq’s SEZs will offer zero duties on trade within the Gulf Cooperation Council and low import duties or exemptions for inputs and machinery.

Qatar’s Minister of Economy and Commerce, Ahmed bin Jassim bin Mohamed al-Thani, said: “This groundbreaking ceremony of Um Alhoul special economic zone is testament to the firm resolve and unwavering commitment of the State of Qatar towards a strategically and fully diversified economy.”

A company set up in such a Free Zone offers benefits to owners including:

• 100% ownership( A single individual is required for setting up (no sponsor required))
• Tax exemption
• Owning properties is allowed (25 years lease options, warehouse facilities, availability of areas for production and assembling etc.)
• Fair renewal fees
• Confidentiality of your business is maintained
• Allowed to open bank account in Dubai
• No restriction for doing more than one activity
• Can wind up at your discretion

The best known jurisdiction for Trade Free Zones is Dubai which has  more than 20 Free Zones operating within its confines including:.

• Dubai Airport Free Zone
• Dubai Cars and Automotive Zone (DUCAMZ) also known as Dubai Auto Zone
• Dubai Healthcare City
• Dubai International Academic City
• Dubai Internet City
• Dubai International Financial Centre
• Dubai Knowledge Village
• Dubai Media City
• Dubai Gold and Diamond Park
• Dubai Multi Commodities Centre (DMCC)
• Dubai Silicon Oasis (DSO)
• International Media Production Zone
• Jebel Ali Free Zone
• JLT Free Zone
• Dubai World Central(DWC) Business Park

A number of our clients hold US Real Estate via Offshore vehicles.

What those clients usually do is this:

• They set up an LLC in a state other than where the property is situated; and
• How they structure the LLC is they have the membership units (akin to shares in the case of a Limited Company) in that LLC held by a tax haven IBC (which depending on where the client lives, is usually owned by a tax free Offshore Private Foundation, see below).
• All incomes are passed through the LLC and paid to the member/s leaving the LLC with no Corporate/Business Tax liability in the US (LLCs are treated as partnerships for tax purposes ie as a “flow through entity”. In other words provided all the income is distributed to the LLC’s members by tax year’s end the LLC should not be required to file a tax return).
• Provided there is only one member (shareholder) of the LLC and provided that member is not a US resident or citizen the income can flow through to the member without the LLC having to declare and pay tax in the US on its profits or capital gains
• The tax haven IBC is not liable to pay tax at home on those receipts
• If there are no further holding entities beneath the IBC, and the owner of the IBC lives in a country which has CFC laws, then he/she will have to declare the IBC’s income at home
• But if the owner of the IBC is a tax free Offshore Private Foundation the IBC’s income could be held and or reinvested by the IBC Offshore potentially tax free

Note the above information is based on advice received from a US Accounting firm which is experienced in tax filing for foreign owned Delaware companies.  You would be wise to seek independent US and local tax advice before committing to put together such a structure.

It’n not easy for an “Onshore” government to find out who is behind X Company assuming you set up an Offshore Company (eg an IBC ie International Business Company) in a Privacy Haven ie somewhere which:

(a) has no public register of Directors or Shareholders or owners; and

(b) which has passed laws prohibiting release of ownership info except by Court order.

As regards the latter in most IBC jurisdictions, unless the country seeking ownership info has a a TIEA (ie Tax Information Exchange Agreement – see below which explains what that is) with the country wherein the IBC is incorporated, the Courts only have the power to release that info if the Company or someone closely connected to it has been involved in very serious criminal activity eg drug trafficking, money laundering, terrorist financing, illegal arms dealing etc

Privacy Haven jurisdictions include:

• Seychelles – For detailed info click on this link: https://offshoreincorporate.com/seychelles-offshore-companies/
• Belize – For detailed info click on this link: https://offshoreincorporate.com/belize-offshore-companies/
• BVI – For detailed info click on this link: https://offshoreincorporate.com/products-services/offshore-companies/bvi-tax-free-ibcs/
• Nevis – For detailed info click on this link: https://offshoreincorporate.com/st-kitts-and-nevis-offshore-companies/
• Anguilla – For detailed info click on this link: https://offshoreincorporate.com/anguillan-ibcs/

What is a Tax Information Exchange Agreement?

A Tax Information Exchange Agreement (TIEA) provides for the exchange of information on request relating to a specific criminal or civil tax investigation.

Let’s assume that you set up a Tax Free Offshore Company in a country which has a TIEA with your home/taxing country.

How it works in practice is, if your home state becomes suspicious of your connection to or involvement with an Offshore Company (ie if they think an Offshore Company is being used by you to avoid domestic tax obligations), the Tax Authorities of your home country can request of the Tax Haven Country Government, as of right, (ie if there TIEA has been entered into between the 2 countries) that they give up the name and address of the “underlying beneficial owner” of the company in question.

Although the information isn’t publicly filed this information must/will be kept by the Tax Free Offshore Company’s local Registered Agent who is obliged by law (as a condition of its International Corporate Service Provider’s License) to hand over this information upon request by/to the local Financial Services Authority (who then pass ownership details to the Tax Haven’s Attorney General’s Office who then pass it down the line to the requesting country).

If you’d like to know what TIEAs have been signed by the country where you live please Contact us via email at this address: info@offshorecompaniesinternational.com

International Yacht Chartering, given its international clientele, is a business that lends itself well to “Offshore” Corporate Structuring. Here’s how it will typically work:

1. The yachts will be owned by (or the leases held in the name of) the/a tax free Offshore Company
2. Your international clients will enter into an agreement with the said Offshore Company (which is commonly an “IBC” ie International Business Company)
3. The situs of the agreement (ie the place at which the contract was formed and or services provided) will be deemed in the agreement to be Offshore
4. The nil tax IBC will have a bank account Offshore ideally in a nil tax International Offshore Financial Centre
5. You will want to set up a merchant account facility for your Company so clients can pay you by card (and also ideally by paypal) as well as by bank wire if/as they may prefer
6. Funds are ultimately directed to the Offshore Company’s tax free bank account and receipted free of tax in the first instance
7. Your or your local company will be engaged by the Offshore Company to perform certain functions (eg client liaison, yacht sourcing, fleet maintenance, logistics management etc etc etc)
8. The operating expenses can/will be paid from the Offshore account
9. To cover your local living costs you could draw down regular instalments as wages (or consulting fees) and/or you could access funds using the Offshore Company’s VISA/Mastercard and/or the Offshore Company could loan you money
10. If you want to make substantial purchases onshore eg to buy a car or a piece of realty or shares/investments your tax free IBC could buy these or (eg if you want to make these purchases as discreetly and as privately as possible) your existing IBC could form a subsidiary IBC to buy these
11. The remainder of your Yacht Charter Business profits could be held and/or invested offshore potentially tax free.

Local laws can have an impact. Hence you should seek local legal/tax advice before committing to set up an Offshore Corporate structure such as that described above.

United States software giant Microsoft has defended its right to use Offshore hubs in Ireland, Singapore and Puerto Rico, which helps reduce its tax rate, in a submission to the US federal inquiry into corporate tax avoidance.

It is the latest technology company to claim it pays its fair share of taxes, following similar statements by Google and Apple in their submissions last week.

Microsoft confirmed its overall effective tax rate was well below the standard US corporate rate of 35 per cent.

It said it was working within international tax rules that allowed income it reported on its US tax return “as fully taxable in the US without regard to the location of the customer”.

It is unclear from the submission or the company’s annual reports how much tax the company paid on its Australasian profit s- the company claims it is above the 30 per cent company rate.

But at the same time it goes into an extensive explanation of why Microsoft uses the lower-tax nation of Singapore as a hub for its Australasian operation.

The submission said Microsoft channels its earnings through foreign hubs – it called these “regional operations centres”  - in Ireland, Singapore and Puerto Rico.

This allows it “to licence the rights to use the relevant intellectual property to produce and sell Microsoft products in respective regions” such as Australasia.

“The Singapore ROC group, organised in 1998, supplies products and services to the APAC region, also representing billions in customer revenue earned and operating expenses incurred serving 18 countries throughout Asia Pacific,” the submission confirms.

It said the APAC group operating costs are funded by the Singapore ROC, which employs over 2300 employees and contractors and owns and operates datacentre facilities that distribute software to APAC customers.

“Regional production, marketing and G&A functions are performed by the Singapore ROC,” the submission said. “The profits earned from the APAC business, after appropriate taxable payments to the US group for technology rights and other support and the payment of support fees to the local subsidiaries, are earned primarily by the Singapore ROC group.”

Microsoft said local entities are “generally required to act under the direction of Microsoft with regards to marketing campaigns, pricing, terms and conditions and policies and procedures” .

“The local subsidiaries provide very limited input into the creation of marketing or technology intangibles embodied in the material provided by Microsoft,” the submission said.

Under long-standing international rules, tax is paid where the value is created. Traditionally this has been where companies have had a “physical” location.

But the rise of online commerce deals with intangibles like intellectual property. This has made it easy for corporations to shift the location of their primary value-generating asset, their intellectual property rights, to lower-tax nations.

The practice, while completely legal under the current rules, has come under question as government revenues dry up.

The use of hubs is an annoyance to governments outside the US. In November, the Chinese government hit Microsoft with a $140 million tax bill, becoming the latest of a series of US technology companies accused by the Chinese government of tax evasion.

But Microsoft, which has previously disputed the backdated figure, said the company “complied with the tax rules in each jurisdiction in which it operates and pays billions of dollars each year in total taxes”.

“The resulting income is reported on our consolidated US income tax return as fully taxable in the US without regard to the location of the customer,” it said.

Microsoft said its overall effective tax rate was 20.7 per cent, 19.2 per cent and 23.8 per cent for fiscal years 2014, 2013, and 2012, respectively.

“The reduction from the United States federal statutory rate stems from foreign earnings taxed at lower rates from producing and distributing our products and services through our ROCs in Ireland, Singapore, and Puerto Rico,” the submission said.

“Our foreign earnings, which are taxed at rates lower than the US rate and are generated from our regional operating centers, were 81 per cent, 79 per cent, and 79 per cent of our foreign income before tax in fiscal years 2014, 2013, and 2012, respectively.”

It said the company was working within US, and other foreign tax laws as written. “That is not to say that the rules cannot be improved – to the contrary, we believe they can and should be. Microsoft is supportive of the current discussions regarding changes to international tax laws.”

The key things to note here is

Offshore Companies are commonly used to own/operate IT Services Businesses. In principle here’s how it can work:

• A nil tax offshore company (commonly an International Business Company “IBC”) is incorporated

• The IBC owns the web based business (ie it owns all proprietary items including website, IP, operating software, soft products to be delivered to customers etc)

• All services are provided/delivered via the web or via email

• The IBC is seen to be managed and controlled from – and is seen to be delivering services from –  a nil tax jurisdiction

• Any commercial agreements entered into (and/or terms and conditions agreed to) should clearly state that services are being delivered from x country (ie the Offshore/IBC jurisdiction) and that the contract is formed/closed in that jurisdiction

• An Offshore account (which receives payments via a merchant account) is set up in a nil tax banking centre

• Ideally the server is located in a country which does not tax business on the basis of server location (eg Singapore)

• Customers contract with and pay the IBC. All such monies are banked free of tax in the first instance

• You or your local company would be contracted by the IBC to manage sales/delivery of product/website maintenance/whatever.

• You would invoice the IBC periodically (eg monthly) for this service which income would be assessable income in your home state – though a smart Tax Accountant should be able to assist you to claim a series of expenses against this income (eg home office, equipment, travel, phone/internet/utilities etc) to significantly reduce the amount of tax payable on this income.

• Often there is some kind of intellectual property (“IP”) created as part of or underpinning such a  business (even if it’s just the website/design). It may be advantageous to you down the track if ownership of the business and the IP were held by 2 different entities. What you can do there is set up a 2^nd IBC to own the IP. The first IBC (ie the Trading Company) pays license fees periodically to the 2^nd IBC which fees wold be receipted tax free. This could be advantageous if you wanted to bring ownership of the web-business onshore or if you wanted to sell the business but keep a passive (potentially tax free) income stream

• Ideally once you start to grow you and to add substance you would be wise to set up your MD/Board and or a sales team to take orders and receive income in a low tax onshore environment (eg Hong Kong, Ireland, Singapore, Cyprus etc as per the Amazon/Google model).  

To minimise the chances of the IBC being taxed onshore ideally the IBC should be (and be seen to be) managed and controlled from offshore. How this can be achieved is by including a Nominee Director etc as part of the Corporate structure. For details of how that can work click on these links:

https://offshoreincorporate.com/faq/should-i-engage-nominees-or-should-i-direct-and-hold-the-shares-in-my-offshore-company/

https://offshoreincorporate.com/faq/how-can-i-protect-my-underlying-ownership-of-my-offshore-company-where-a-nominee-is-engaged-to-act-as-director-or-shareholder/

Local laws can have an impact. Hence you should seek local legal/tax/financial advice before committing to register such a structure.