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Given that within the European Union there are no withholding taxes on IP royalties between member states, we can suggest a number of countries where royalties are particularly advantageous.
CYPRUS The intellectual property royalties tax regime in Cyprus has changed as a result of the recommendations of the Organization for Economic Co-operation and Development (OECD) Action Report 5 and the Ecofin Council conclusions published on 8 December 2015. Legislation has been changed to limit the companies that can benefit from research and development (R&D) exemptions, but the tax rate in Cyprus is still one of the most favorable in the EU for foreign companies using Cyprus intellectual property want to license -resident companies (intermediaries), where this right is then sub-licensed to the end user. Overall, the effective tax on IP royalty income should be less than 2.5%.
IRELAND In 2015 Ireland introduced an effective corporation tax rate of 6.25% on intellectual property income based on an allowance for research and development costs borne by the company. By linking the two components in this way, Irish law encourages companies to conduct R&D directly within the EU - leading to the creation of intellectual property - while discouraging them from acquiring licenses without directly committing to R&D.
BELGIUM Belgium has introduced a tax system that favors those with income from acquired copyrights. This tax regime can have many different applications and can be used to protect artworks as well as a useful tax break for IT developers. Income from IP rights royalties is taxed at 15%. This income is not taken into account when calculating social security contributions. In addition, these taxes are reduced by 50% for imports due to the application of standard import costs. The first €15,000 that a copyright owner earns in a year is therefore taxed at 7.5%, and the next €15,000 at 11.25%. This tax system applies to people with a total annual income of up to 56,450 euros.
LUXEMBOURG In general, corporate tax in Luxembourg is 29.22%, but for IP licensing income it can be as low as 5.8%. This is due to an 80% corporate income tax exemption. Interestingly, this exemption also applies to companies that have registered a patent for use in connection with their own business, which then calculate a notional net income as if they had received the licensing income.
ITALY Italy is a larger market compared to the other countries discussed and can be a very attractive place for a company to invest in R&D since 2015 companies have been able to deduct intellectual property income from their taxable income base. The tax deduction was set at 30% in 2015, 40% in 2016 and 50% from 2017. Businesses will therefore enjoy a significant tax rebate by reducing their taxable income.
THE NETHERLANDS Since 2010, IP income has been taxed at only 5% in the Netherlands. Except for patents, there is no income limit. Patent holders can actually have access to this tax regime if their share of the expected revenue is between 30% and 70%, taking into account the total combined revenue from patents and other sources. These rates also apply to foreign companies owning intangible assets or companies that have received research and development accreditation from the Dutch Ministry of Economic Affairs if they are owners of software IP or trade secrets. The only other caveat to this favorable tax regime is that it doesn't apply to marketing and branding-related assets.
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Membership in International Unions Whether it is an alliance, incorporated union, federal union or supranational body here is the list of unions the country is a member of. Germany is a member of several unions. They are European Union, International Monetary Fund, North Atlantic Treaty Organization, Organisation for Economic Co-operation and Development, Schengen Area, United Nations, World Bank, World Trade Organization.
European Union Germany is a member of European Union. On 1 January 1958, it joined the EU as a full member state. The EU is a unique economic and political partnership between 28 European countries that together form a politico-economic union and cover much of the European continent. It covers an area of 4,324,782 km, with an estimated population of over 508 million. People can travel freely throughout most of the continent. Operating as a single market, the EU is a major world trading power. And it's become much easier to live, work and travel abroad in Europe.
International Monetary Fund Germany is a member of International Monetary Fund. On 14 August 1952, it joined the IMF as a member. The IMF is an organization headquartered in Washington, D.C., of 189 countries working to foster global monetary cooperation, secure financial stability and facilitate international trade. The IMF now plays a central role in the management of balance of payments difficulties and international financial crises. The union is governed by and accountable to the all 189 member countries. As of 2010, the fund had SDR 476.8 billion (about US$ 755.7 billion).
North Atlantic Treaty Organization Germany is a member of North Atlantic Treaty Organization. Germany has been a part of NATO since 6 May 1955, and therefore has been a member of NATO for 68 years. The North Atlantic Treaty Organization (French: Organisation du Traité de l'Atlantique Nord; OTAN) is an intergovernmental military alliance based on the North Atlantic Treaty which. NATO's headquarters are located in Haren, Brussels, Belgium. NATO promotes democratic values and encourages cooperation on defence and security issues. The organization constitutes a system of collective defence whereby its member states agree to mutual defense in response to an attack by any external party. NATO is committed to the peaceful resolution of disputes.
Organisation for Economic Co-operation and Development Germany is a member of Organisation for Economic Co-operation and Development. On 27 September 1961, it joined the OECD as a member. The Organisation for Economic Co-operation and Development (French: Organisation de coopération et de développement économiques, OCDE) is an international economic organisation of 34 countries, founded in 1961 to stimulate economic progress and world trade, and promote policies that will improve the economic and social well-being. It is a forum in which governments can work together to share experiences and seek solutions to common problems. OECD work with governments to understand what drives economic, social and environmental change. OECD measures productivity and global flows of trade and investment.
Schengen Area Germany is a member of Schengen Area. On 26 March 1995, it was accepted into Schengen Area. The Schengen Agreement is a treaty which led to the creation of Europe's borderless Schengen Area. It entitles every EU citizen to travel, work and live in any EU country without special formalities. It was signed on 14 June 1985 by five of the ten member states of the then European Economic Community near the town of Schengen, Luxembourg. Schengen cooperation enhances free movement of persons by enabling more than 400 million EU citizens to cross internal borders without being subjected to border checks.
United Nations Germany is a member of United Nations. On 18 September 1973, it joined the UN at its inception date as a full member state. Founded in 1945, the United Nations is an intergovernmental organization to promote international co-operation. The work of the United Nations are guided by the principles contained in its founding Charter. It is currently made up of 193 Member States. The headquarters of the United Nations is in Manhattan, New York City, further main offices are situated in Geneva, Nairobi and Vienna. Its objectives include maintaining international peace and security, promoting human rights, fostering social and economic development, protecting the environment, and providing aid.
World Bank Germany is a member of World Bank. On 14 August 1952, it became a member of the World Bank Group. The World Bank is international financial institution that provides loans to developing countries. It's like a cooperative, made up of 189 member countries. These member countries are represented by a ministers of finance who are the ultimate policymakers at the World Bank. The World Bank's official goal is the reduction of poverty.
World Trade Organization Germany is a member of World Trade Organization. On 1 January 1995, it joined the WTO as a member. The World Trade Organization is an intergovernmental organization which regulates international trade. At its core are the WTO agreements ratified in national parliaments. It is the only global international organization dealing with the rules of trade between nations. The goal is to help producers of goods and services, exporters, and importers conduct their business. The WTO deals with regulation of trade between participating countries by providing a framework for negotiating trade agreements and a dispute resolution process aimed at enforcing participants' adherence.
IBC or International Business Company or as it is also called International Business Corporation is basically an offshore company that is usually incorporated under the laws of some jurisdictions worldwide as a tax neutral company, meaning that it is not subject to tax in the country of incorporation. It is also limited in the direct business activities it may engage in while operating in the context of the jurisdiction in which it is incorporated.
Importance and main functions of IBC Often IBC features can vary by jurisdiction, but typically include confidentiality of business records, ability to issue shares, provision of a local registered agent or office, and exemption from local corporate income tax as the majority of offshore Jurisdictions that removed or are processing removal exempt IBC from local taxation while reducing corporate income tax to zero to avoid hurting the entire offshore finance industry.
Such companies are generally formed for offshore banking, international investment, asset protection, real estate and intellectual property ownership, and other business activities related to international trade.
A list of jurisdictions offering IBC as a business structure As stated in Streber Weekly, there are many jurisdictions that offer IBC as a business structure. The list of such jurisdictions is quite long: Antigua and Barbuda, Anguilla, Barbados, Bahamas, Belize, Brunei, British Virgin Islands or BVI, Cook Islands, Comoros, Dominica, Grenada, Gambia, Mauritius, Marshall Islands, Monsterrat, Nauru, Saint Lucia, Samoa, St. Kitts and Nevis, St. Vincent and the Grenadines, Seychelles and Vanuatu. This list includes most jurisdictions without considering their worldwide reputation. Some popular offshore jurisdictions not mentioned previously offer territorial taxation and other tax incentives in lieu of IBCs. These business structures can operate as Exempt Corporations, Free Zone Corporations, or Non-Resident Corporations, etc. without having the ease of IBC corporations: Panama, Hong Kong, Cayman Islands, Turks and Caicos Islands (TCI), United Arab Emirates (UAE), Bermuda.
For example, the jurisdiction of Panama is generally appropriate for International Foundation or IBC in terms of asset protection. The jurisdiction of Hong Kong in general is also convenient for international trade due to the favorable tax system as no withholding tax, capital gains tax, capital gains tax, VAT and other types of taxes are levied.
The most respected jurisdictions for IBCs The British Virgin Islands (BVI) is recognized as the world's leading offshore business center with more than 450,000 operating companies registered on its territory. He is often referred to as the grandfather of all IBCs. International international business corporations have a fairly good reputation among other jurisdictions of this type due to the ability to transfer domicile and privacy of ownership for assets collected within the corporation. In general, the BVI provide flexible, cost-effective and fast international offshore company formation services.
Seychelles can be alternatives to BVI offshore companies as this jurisdiction also offers ease of administration, simplicity and privacy. Additionally, with more than 175,000 companies registered there, IBC is the most common type of company formed on islands. The IBCs of this jurisdiction are commonly used as consulting and staffing services firms, as well as holding companies for stocks, real estate, and stocks.
The Bahamas is one of the oldest offshore jurisdictions to be considered classic like the previously mentioned BVI as it is independent, politically stable, has an improving reputation and is gambling friendly.
Saint Kitts and Nevis has a good reputation but is also politically stable and has an average to low cost. However, this jurisdiction is more popular for its limited liability companies (LLC).
St. Vincent and the Grenadines has low costs. It is quite stable politically and has a good reputation which has improved in recent years due to increasing popularity due to financial deals conducted by Euro Pacific Bank and Loyal Bank.
Belize is also a great place for IBC formation. Within this jurisdiction, IBC may provide international trade, asset protection, offshore banking, real estate ownership, e-business or other financial services
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Taking into consideration aspects like tax regime, substance requirements and confidentiality, we would strongly recommend that you choose one of the following jurisdictions for your holding structure:
Malta: Dividend income can be 100% exempt of corporate tax, if the Maltese company a) holds at least 10% of the shares of the foreign subsidiary, or b) invests more than EUR 1.5 million in its subsidiary. Note that the subsidiary company must also either a) be domiciled in the European Union, b) pay at least 15% corporate tax in its country of domicile or c) generate its revenue mainly from trading activities.
The Netherlands: The Dutch B.V. offers a great holding regime, with no minimum period for holding shares, no corporate income tax on dividend income and no capital gains tax from the sale of shares. However, you must adhere to a number of participation exemption rules: foreign subsidiaries must either a) be trading companies, or b) pay corporate tax of at least 10% in the countries where they are registered.
Singapore: Corporate taxation in Singapore works on a one-tier basis, meaning that the 17% tax on corporate income is charged once and is final. Dividends distributed to shareholders are therefore not subject to additional withholding tax.
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With the right documentation and initial expenses, it is possible for a foreign citizen to open a bank account in New Zealand. This international account and investment opportunity offers several advantages based on economic regulations and tax structures. Interest rates, tax laws and fees vary depending on the country in which you invest; Careful research and strategic financial actions could result in significant portfolio growth.
If you are considering opening a bank account in New Zealand, you need to enlist the help of international experts to guide you through the process.
Legal structures in New Zealand Each international jurisdiction adheres to different legal structures for taxation and banking. Confidus Solutions helps you understand the nuances of each country's legal structure. In order to do business in New Zealand, it is crucial that you have a thorough understanding of the financial and legal ramifications.
Initial investments The vast majority of bank accounts in New Zealand require an initial financial outlay to secure the account opening. This value differs from bank to bank and also depends on variable exchange rates. An international financial expert will help navigate these conversions, as well as the various fees and minimums associated with maintaining a bank account. Make sure you understand the interest and growth rates associated with each prospective international bank account so you can maximize your returns while minimizing risk.
Tax structures in New Zealand To get the best results and avoid bureaucratic and legal pitfalls, enlist the support of an expert in international finance and economics. This initial investment in proper processes and research will help avoid a litany of long-term costs and fees related to unforeseen errors and legal errors. Language skills, financial know-how and bureaucratic experience ensure that your account opening is processed smoothly and without unintended consequences.
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You can incorporate a 'sharikat al-mossahamah' in Egypt or a 'société anonyme' in Morocco; these are generally the most common legal structures for companies throughout all of Africa. In Egypt, you can also incorporate an SAE, an LLC and several other types of legal entity. SAE in Arabic stands for “sharikat al-mossahamah”, and closely resembles the United Kingdom’s plc. LLC in English stands for “limited liability company”, which is very similar to the United Kingdom’s limited company. Before registering a company, you should have a thorough understanding of all the advantages and disadvantages of each African jurisdiction, including Comoros, Mauritius, the Seychelles, Cape Verde, Mayotte, the Madeira Islands and the Canary Islands.