What to do if the traditional tax planning can not be used, and high taxes do not want to pay?
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Fighting offshorami severely restricted the use of traditional offshore jurisdictions.
Fooling these restrictions and to get rid of offshore image using the composite structures.
First, visible to outsiders, a part of such a structure - a company of respectable country with the usual taxes. This so-called. «Facade» company. Suspected it to minimize taxes is almost impossible.
"Fasadnaya" the company concludes an agency agreement with an offshore company. In accordance with this agreement, «facade» company is an agent offshora and operates on its own behalf but on behalf of offshora. Offshore undertakes to pay agent commissions as a percentage of net sales.
Composite scheme
In some jurisdictions, agent fees can be fixed.
The most popular "facades" in such schemes - companies from the UK and Ireland. Sometimes used by the Danish, French and German companies.
For more privacy final owner of shares "front" companies can trust to transfer trust or private foundations.
Multi-tier scheme used in the holding company. "Facade" here is a company from a jurisdiction with a treaty on the elimination of dvoyonogo taxation to the country from which derive profits. During the "facade" is a company of nizkonalogovogo State, which has convenient agreement on the avoidance of double taxation with a "facade". An example of this pattern: Belgium + Hong Kong.
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