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Professional Services or Consultancy
For individuals who receive substantial income in respect of their professional services, such as architects, performing artists or consultants, with an extensive international client portfolio requiring substantial travelling, the incorporation of a low taxed company through which the international operations can be performed can be interesting from tax planning perspective. The right to receive the fees can be assigned to the low tax company, which can conclude the contracts with the various clients and can employ the professionals rendering the services in practice. In other words, the low tax company would contract with the ordering party for the performance of the relevant work, and would invoice and receive payments accordingly. As such, the profits would be realised in the low tax jurisdiction. The company can also invoice the group companies located in high tax jurisdictions, thus eroding high taxable bases and lowering the group's overall tax liability. One should be aware, however, that in the latter kind of situations the so-called “arm’s length principle” be taken into account, in general meaning that the remuneration received by the low tax company should be equal to what independent parties agree or would have agreed under similar circumstances. Suitable jurisdictions within the EU are Cyprus and Malta.
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