IMI

Kidson · Post by **Kidson** » Sat Jun 21, 2003 9:04 pm

I also get the-news.net and noticed no article re: offshore - hence my request to extrapolicate if not all, at lease the gist and salient points from the article.

Guest · Post by **Guest** » Sat Jun 21, 2003 11:19 pm

i dont know how to transcribe the article from paper to here as i dont have a scanner...you might like to contact finespo direct for perhaps a copy tel 282 561 333.

in summation it is more or less a rehash of what we already know but the advice if i can be so bold is to get out of offshore before the end of this year transfering the property to the persons name at a low figure as possible to get away with and hope no one challeges it

Offshore Owner · Post by **Offshore Owner** » Thu Jun 26, 2003 9:21 am

transferring property at an articiafially low price will be difficult to achieve and owners risk being challenged and if upheld their properties valued and taxed at the correct price. This could prove to be very costly! Try if you like but it is a bet!

Guest · Post by **Guest** » Mon Jun 30, 2003 4:06 pm

Avice from a friend in portugal. At the moment there is a list of 82 locations that are effected by the new laws.Two locations which are not on the list ,i hear, are Malta and Oklahoma.If this is true it may be worth moving your offshore company,s location.

Guest 2 · Post by **Guest 2** » Mon Jun 30, 2003 5:02 pm

And apparently Delaware

But what are the chances of our Portugues friends adding Malta, Oklahoma et al to the list. If this happens then back to first base!

Guest · Post by **Guest** » Tue Jul 01, 2003 2:26 pm

So why didn,t they put them in in the first place.

Guest 2 · Post by **Guest 2** » Tue Jul 01, 2003 5:58 pm

Precisely!

Probably something to do with blacklisting USA states. If that were to happen I would think George W would have a few aircraft carriers offshore of Portugal himself!!!

biffa · Post by **biffa** » Wed Jul 02, 2003 5:43 pm

Both USA and Malta used to be on Portugals fiscal blacklist but no longer. The blacklist compises any country with a corporate tax rate of 60% or less than Portugals (ie 18% or under) That is why there are 83 territories on it including the well known offshore centres of Tristan da Cunha and the Yemen Republic.

Malta just doesn't fit the bill. It is a tax treaty partner of Portugal, ithasa corporate tax rate higher than Portugals and its tax and corporate legislation have passed EU scrutiny prior to EU entry.

Delaware is a bit of an odd one. The simple Delaware Corporation is not liable to Delware State taxes but is liable to US Federal Taxes and I would not like to share my bed with the IRS.

The Delaware corporate structure that IS tax friendly is a Delaware Limited Liability Company (LLC) which is taxed on a sort of of partnership basis - in other words the entity is not taxed but the partners are. Use non resident partners in a tax neutral country and bingo - no tax. That is the idea.

Keep watching this Forum and soon all will be revealed! I can't promise great news but some ideas and solutions.

Kidson · Post by **Kidson** » Wed Jul 02, 2003 9:02 pm

I think I am correct in saying the UK also does not appear on the blacklist of countries.

Guest 2 · Post by **Guest 2** » Wed Jul 02, 2003 9:08 pm

Biffa - So in your opinion Malta is the place to re domicile an offshore Co to for the short to medium term. I thought that they don't operate Offshore Co's in thetruest sense but holding Co's Do the holding Co's offer trhe same CGT benefits etc?

biffa · Post by **biffa** » Thu Jul 03, 2003 10:40 am

Malta looks a good jurisdiction. You are right that they are NOT offshore and that is why they are acceptable. The old Malta offshore regime was ended back at the end of 1996 in readiness for their EU application. There is CGT in Malta but CGT should not normally be a concern in the place of incorporation of a property company. It is a concern if a company sells an asset but then CGT would become payable here in Portugal anyway and set off aganst any Malta tax under the treaty. CGT can be a concern in the tax residence of the company owner and local advice on taht is necessary.

The UK is not on the list but you can't redomicile to the UK so a non starter from that point of view.

kteee · Post by **kteee** » Thu Jul 03, 2003 2:03 pm

Biffa, Do you know if Abbey National still going to insist on offshore ownership? If so, surely their offshore lending days are over.

kt

Offshore Owner · Post by **Offshore Owner** » Thu Jul 03, 2003 4:10 pm

Kteee,

They are considering the impact of the changes and will revert in due course - what that means in reality is they will announce their policy in 6 months time after which it is far too late for anyone to react in time for the 1st January. I would suggest that you write to them in the Isle of Man and push them to respond quickly and postively.

Graham · Post by **Graham** » Thu Jul 03, 2003 4:34 pm

Having been trying to contact them for two months by phone and email with no response whatsoever I am not sure they know the meaning of the words 'quickly' or 'positively'

Guest 3 · Post by **Guest 3** » Thu Jul 03, 2003 4:50 pm

They are so poor in responding but anyone who has mortgaged with should contact :

Mark Barlow in the Isle Of Man who seems to be coordinating this project for Abbey

Black list

IMI etc

Abbey National