Month: July 2021

When to use an Isle of Man Foundation (3 of 3)

Posted on | by Charlotte Clabon

People often say that a Foundation is the civil law alternative to a Trust; but what does this mean? What does a Foundation offer your clients that a Trust cannot? Furthermore, when does it make sense to use a Foundation? Add on top of that the fact that you can validly use both entities in tandem, the clear contrast we were hoping for begins to look grey – but hopefully this article can provide some clarity.

This is the third article in a three-part series we have produced on Foundations. If you would like to reacquaint yourself with the basics of Isle of Man Foundations or the technicalities of setting up and administering one, please refer back to the previous articles in this series:

In this article we will be examining some of the most common uses of Isle of Man Foundations (IOM Foundations), which includes:

Using an Isle of Man Foundation for Succession Planning

Unlike a Trust, an IOM Foundation is an incorporated vehicle, having separate legal personality; similar to a Private Limited Company, but without shareholders. As such, the IOM Foundation has the capacity to enter into contract, own property and take legal action in its own right.

As an Isle of Man corporate vehicle the IOM Foundation is a ‘Corporate Taxpayer’ under s120(ba) of the Income Tax Act 1970, and benefits from the local tax regime, boasting headline rates such as:

Because an IOM Foundation is not answerable to shareholders and is perpetual in term, it is free to pursue its Founder’s intended Objects for as long as stipulated in the Foundation Rules. For these reasons, the IOM Foundation can be a great choice for those seeking to ensure the continuation of their life’s work, whether a successful business or charitable pursuits.

The IOM Foundation can be established for the purpose of purchasing and owning the shares of a company, either retaining profits for future growth or making distributions to classes of beneficiary, in line with the IOM Foundation’s Instrument and Rules.

Furthermore, once the IOM Foundation has been registered, unlike a Trust, it will receive a certificate of incorporation, which can be useful for evidencing existence when dealing with institutional lenders and third parties, for example. To this end, an IOM Foundation could be used as a Special Purpose Vehicle, with one of its Objects being to secure capital for the business via loans that will not appear on the company’s balance sheet.

IOM Foundations can deliver a level of assurance and control that make them an ideal vehicle for succession planning.

Using an Isle of Man Foundation for Asset Protection

One of the most common uses of the IOM Foundation is asset protection, particularly with regards to Estate Planning. The Founder can dedicate assets (usually capital) into the corporate vehicle. Following this, the Foundation Council will manage and distribute the funds in line with the Foundation Rules and Instrument, as prescribed by the Founder.

Non-charitable IOM Foundations require an Enforcer to be appointed, who ensures the Council carries out its functions in compliance with the constitutional documents. Whilst the Founder can be appointed as Enforcer, it is recommended that they are not; very often it will be a trusted adviser who might act as Enforcer. However, the Founder can be, and often is, appointed as a Council Member; allowing them to retain some control to ensure that their goals come to fruition, potentially without jeopardising their tax position.

Not only does the IOM Foundation provide a clear and enforceable roadmap for the Council Members to follow, due to its legal personality it might also be used to mitigate tax liabilities, particularly inheritance and wealth taxes. The IOM Foundation will be domiciled in the Isle of Man, therefore being subject to the Manx tax regime i.e. 0% IHT, for example.

The IOM Foundation is also appropriate for the mitigation of Forced Heirship laws.  As the structure is resident in the jurisdiction of registration, therefore the laws of the Isle of Man are applicable. Any challenge to the IOM Foundation will be heard in an Isle of Man Court and, for example, laws seeking to challenge the validity of the IOM Foundation can be set aside, in conformity with the Foundations Act 2011.

IOM Foundations are not currently a matter of public record, meaning the identities of the Founder, and any Donors or Beneficiaries are a private matter.

Depending on the IOM Foundation’s constitution, the Foundation’s Rules which will deal with the appointment or removal of any parties, such as Enforcer, Beneficiaries etc., can be altered at any time. This flexibility allows for any change in wishes or circumstance.

The IOM Foundation can also be used to ringfence assets and wealth exposed to both creditors or spouses etc. making it a great all-round tool for asset protection.

Using an Isle of Man Foundation as Trustee

Both Foundations and Trusts provide mechanisms for the transfer of beneficial ownership, from donor to beneficiary – this may make it seem like it’s always an either-or scenario, but it isn’t. In some circumstances the two vehicles can complement one another to further meet the client’s objectives.

The IOM Foundation can be appointed as Trustee, providing a function similar to a Private Trust Company. This provides some or all of the benefits of appointing a Professional Trustee, depending on the choice of Council Members. Such benefits can include:

  • Continuity
  • Neutrality
  • Technical Knowledge
  • Mitigating Risk 

In addition, the Settlor can also be appointed as Council Member to retain some oversight, ensuring the purpose of the Trust is realised. This may provide the Settlor with some degree of comfort following the transfer of his assets to a new fiduciary service provider.

As you can see, using the two entities in tandem can help deliver added flexibility with regards to activity and increased oversight concerning the purpose in mind.

Using an Isle of Man Foundation for Charitable Objects

The IOM Foundation is also commonly used as a philanthropic vehicle. The IOM Foundation can be either dedicated to charitable or a mixture of charitable and non-charitable Objects. If established for purely philanthropic pursuits, the IOM Foundation’s Objects cannot be altered to include non-charitable activities in the future.

The IOM Foundation may be of particular relevance to clients seeking to engage in philanthropic activities in jurisdictions that do not recognise trusts.

There are broadly two categories of charitable IOM Foundation, each with its own purpose:

  1. A non-operating charitable IOM Foundation is established to make grants to other not-for-profit or charitable organisations. In practice this may be the donation of income from its underlying assets or further donations from the Founder/Donors, or blend. Classes of Beneficiaries can be limited to a single organisation or cause as desirable.
  2. An operating charitable IOM Foundation seeks to engage in charitable activities directly, taking responsibility for fulfilling its charitable Objects. Examples of such operating charitable IOM Foundations include; museums, educational institutions, and community initiatives.

The IOM Foundation can be used flexibly for the benefit of whatever cause or organisation is close to the Founder’s heart.

Dixcart Supporting the Establishment and Administration of Foundations

At Dixcart, we offer a full suite of offshore services to advisers, and their clients, when considering the establishment of an IOM Foundation. Our in-house experts are professionally qualified, with a wealth of experience; this means we are well placed to support and take responsibility for different roles, including acting as Registered Agent or Council Member, as well as providing specialist advice when required. 

From pre-application planning and advice, to the day-to-day administration of the Foundation, we can support your goals at every stage.

Get in touch

If you require further information regarding Isle of Man Foundations, their establishment or management, please feel free to get in touch with David Walsh at Dixcart: advice.iom@dixcart.com.

Dixcart Management (IOM) Limited is licensed by the Isle of Man Financial Services Authority.

Importance of having a will

Important Considerations – UK Formerly Domiciled Residents

Posted on | by Charlotte Clabon

Important Considerations – Formerly Domiciled Residents

Background

When individuals are thinking of returning to live in the UK, there are a number of important matters they should consider before they move back to the UK.

This article focuses on Formerly Domiciled Residents (FDRs), who are non-UK domiciled under general law, but are deemed to be domiciled in the UK for taxation purposes.

Formerly Domiciled Residents and Liability to UK Tax

Anyone born in the UK with a UK domicile of origin will always be an FDR if they resume residence in the UK, irrespective of how many years they have lived abroad or whether they have any connections to the UK.

These individuals will pay UK tax on their worldwide income and capital gains, on the same basis as taxpayers who are UK domiciled under general law. Any potential tax advantages which might have been obtained by these individuals, by reason of their UK non-domiciled status, are therefore removed.

Who is a FDR?

A formerly domiciled resident (FDR), is a non-UK domiciled individual who:

  1. Was born in the UK; and/or
  2. Has a UK domicile of origin; and
  3. Is UK resident for the tax year.

Deemed UK domicile is triggered on 6 April in a tax year of UK residence,even if this year is a ‘split’ year under the statutory residence test (SRT).

An individual normally acquires a domicile of origin from their father at birth, or from their mother, if the parents were not married. This is not necessarily the country in which that individual was born.

If an individual does not meet any of the automatic overseas tests but does meet one of the automatic UK tests, or the sufficient ties test, they will be considered a UK resident.

UK Inheritance Tax and Trusts

Assuming an individual meets the above FDR criteria and was resident in the UK in at least one of the two previous tax years, prior to the year in which any Inheritance Tax (IHT) charge arises, property settled into a trust, when they were not domiciled in the UK, cannot be excluded for the purposes of IHT. 

This could have severe consequences with the Trust falling into the ‘Ten Yearly and Exit Charge Regime’. If the Settlor (or his spouse or civil partner) has retained a benefit, the ‘Gift with Reservation of Benefit’ provisions will apply, and a charge to tax on the death of the Settlor will be imposed. Please speak to Dixcart UK, if you would like more details regarding either potential consequence.

It is also important to seek professional advice to understand how specific individuals and clients might be affected and any action that might need to be taken before individuals become UK resident.

Summary

An individual’s domicile status is a fundamental factor in determining his/her liability to UK tax. It also has implications for other branches of the law.

UK Non-domiciled Individuals and Planning

Careful planning and consideration must be taken in order to take advantage of potential tax exemptions, reliefs and protection from inheritance tax which can be obtained by UK non-domiciled individuals.

Due to HMRC’s increased investigations into the tax affairs of UK non-domiciled individuals,   a robust defence should be prepared, in the event of any challenge from HMRC. Professionals at Dixcart UK can help you prepare a ‘domicile review’, to provide evidence of your intentions, supported by the facts. This can be particularly useful in situations where enquiries are opened by HMRC after death.

Contact Details

If you require additional information on this topic and further guidance regarding your domicile status, please contact your usual Dixcart adviser or speak to Paul Webb or Peter Robertson in the UK office: advice.uk@dixcart.com

The Attractive Malta ‘Highly Qualified Persons Scheme (HQPS)’ – Enjoys an Extension

Posted on | by Charlotte Clabon

Highly Qualified Persons Scheme – A Need for Additional Highly Qualified Individuals in Certain Sectors

Since joining the EU in 2004, Malta has been modernising its economy. It is becoming recognized as a high functioning, low cost, and well-regulated jurisdiction with an underlying theme being the availability of trained staff thanks to Malta’s high investment in education and training. The expansion of the financial, aviation and gaming sectors, since Malta joined the EU, and the associated increase in demand for technical skills has in recent years however, highlighted the need for additional highly qualified workers. There is a need to attract individuals with sufficient existing knowledge to Malta, particularly in these sectors of; financial services, gaming, aviation and the associated support services. The Highly Qualified Persons scheme was introduced to attract these individuals.

The objective of the Highly Qualified Persons Rules (SL 123.126), was the creation of a programme to attract highly qualified persons to occupy ‘eligible office’, with companies licensed and/or recognized by the Competent Authority regulating the specific sector.

Benefits of the Highly Qualified Persons Scheme

The scheme is targeted at professional individuals, earning more than €86,938 in 2021, and seeking to work in Malta.

  • The qualifying individual’s tax is set at a highly competitive flat rate of 15%, with any income earned over and above €5,000,000 being tax exempt.

The standard alternative in Malta, would be to pay income tax on a sliding scale, with a current maximum rate of 35%.

2021 Update of the HQPS in Malta

Changes were recently introduced in 2021 and were made retrospective as from 31st  December 2020.

These changes consist of:

  • The HQPS has been extended for five years.

No changes to the scheme will now be made until 31st of December 2025. Some variations to the scheme might potentially be made to HQPS, for relevant employment in Malta that commences between 31st of December 2026 and 31st of December 2030.

  • Individuals enjoying HQPS now have two different extension options, depending on their nationality: five years for EEA and Swiss nationals, and four years for third-countries nationals.

Definition of an ‘Eligible Office’

‘Eligible office’ in the financial, gaming, aviation and associated supporting services sectors, including any organisation holding an air operator’s certificate,  is defined as employment in one of the following positions:

• Actuarial Professional

• Aviation Continuing Airworthiness Manager

• Aviation Flight Operations Manager

• Aviation Ground Operations Manager

• Aviation Training Manager

• Chief Executive Officer

• Chief Financial Officer

• Chief Commercial Officer

• Chief Insurance Technical Officer

• Chief Investment Officer

• Chief Operations Officer; (including Aviation Accountable Manager)

• Chief Risk Officer; (including Fraud and Investigations Officer)

• Chief Technology Officer

• Chief Underwriting Officer

• Head of Investor Relations

• Head of Marketing; (including Head of Distribution Channels)

• Head of Research and Development; (including Search Engine Optimisation and Systems Architecture)

• Odds Compiler Specialist

• Portfolio Manager

• Senior Analyst; (including Structuring Professional)

• Senior Trader/Trader

Other Applicable Criteria

In addition to individuals having a qualifying position, as detailed above,  individuals must also meet the following criteria:

  • The applicant’s income must be derived from an ‘eligible office’, and must be subject to income tax in Malta.
  • The applicant’s employment contract must be subject to Maltese Law and is for the purpose of genuine and effective work in Malta. This must be demonstrated to the satisfaction of the Maltese Authorities.
  • The applicant needs to provide proof to the authorities that he/she has appropriate professional qualifications, and has at least five years’ professional experience.
  • The applicant must not have benefitted from any other deductions available to ‘Investment Service Expatriates’, as detailed in the terms of Article 6 of the Income Tax Act.
  • All salary payments and expenses must be fully disclosed to the authorities.
  • The applicant must prove to the authorities that:
  • He/she is in receipt of sufficient resources to maintain himself/herself and members of his/her family, without recourse to public funds.
  • He/she resides in accommodation regarded as normal for a comparable family in Malta, which meets the general health and safety standards in force in Malta.
  • He/she is in possession of a valid travel document.
  • He/she possesses sufficient health insurance for himself/herself and members of his/her family.
  • He/she is not domiciled in Malta.

Summary

In the right circumstances, the Highly Qualified Persons Scheme provides taxation advantages for professional high net worth individuals who want to move to Malta and work on a contractual basis there.

Additional Information

If you would like further information regarding the Highly Qualified Persons Scheme and opportunities available through Malta, please speak to Jonathan Vassallo, or Henno Kotze: advice.malta@dixcart.com, at the Dixcart office in Malta or your usual Dixcart contact.

Dixcart Management Malta Limited Licence Number: AKM-DIXC-23

What Are The Tax Benefits Available in Portugal For Digital Nomads and Other Individuals Moving There?

Posted on | by Charlotte Clabon

The Rise of Digital Nomads

Following on from the restrictions caused by the pandemic and the significant increase of people no longer working in an office, or place of work, a number of individuals have realised that they can work from ‘anywhere’. Portugal offers a temporary residence visa that can be used by freelancers and entrepreneurs, which digital nomads can take advantage of.

Digital Nomad Village in Madeira, Portugal

The local government in Madeira has launched the ‘Madeira Digital Nomads’ project, to attract foreign professionals to the island. Those taking advantage of this initiative can live in the nomad village in Ponta do Sol, in villas or hotel accommodation and enjoy free; wi-fi, coworking stations, and specific events.

The Attractions of Portugal – to a Wide Audience

Portugal is an attractive and popular location – not only for digital nomads to move to – but for a large variety of individuals, in many different circumstances.

Not only is it a beautiful country, offering an attractive lifestyle, but it also offers the popular Golden Visa (GV), and the Non Habitual Residents (NHR) programme, which can be combined, and offer a route for individuals to move to Portugal and to enjoy tax advantages once they re-locate here.

The GV is less important for EU citizens, as they already have a right to live in Portugal without formal immigration or investment being required.

  • NHR has proved to be a major motivator for both EU and non-EU citizens.

Key Advantages of Portugal NHR status:

Portugal is a full member of the EU and therefore legal residents can travel freely and visa-free throughout the EU under Schengen.

NHR status lasts for ten years.

Tax efficiencies in relation to NHR status include:

  • It is possible, with careful structuring, for NHRs to not be taxed on income, other than Portuguese-source income, for the ten year NHR designated term.
  • Recent amendments now include a tax of 10% on pension income, which remains considerably less than the standard Portuguese tax on pensions.
  • 20% flat rate for certain Portuguese source income (from specific professions and from self-employment), as opposed to standard Portuguese income tax rates of up to 48%.

Criteria to Meet NHR Status

The following criteria must be met:

  • The right to reside in Portugal, either by being an EU/EEA/Swiss citizen, or through schemes such as the Golden Visa programme.
  • Must not have been resident in Portugal within the last five Portuguese tax years.
  • Must not have been a Portuguese tax resident in the five years prior to taking up residence in Portugal.
  • The individual must have a place to live in Portugal, this could be the rental of a modest apartment.
  • To apply for NHR, a fiscal representative, such as Dixcart, needs to be appointed in Portugal.

Additional Information

If you require additional information regarding moving to Portugal, please contact Catarina Sardinha in the Dixcart office in Portugal: advice.portugal@dixcart.com.

Recent Changes to The Malta-Poland Double Tax Treaty

Posted on | by Charlotte Clabon

Background

The Malta – Poland Double Tax Treaty (DTT) has recently been revised with amendments being published as Legal Notice 64 of 2021. The changes are aimed to eliminate base erosion and profit shifting (BEPS), with the Treaty being based on the OECD Model Tax Convention.

Modifications were made to Articles relating to the following; dividend definition, withholding tax on interest, royalty income, capital gains from the sale of shares, and director’s fees, the method of elimination of double taxation, the mutual agreement procedure, the exchange of information to provide for tax arbitration, and  prevention of treaty abuse.

These changes are outlined below:

  • The definition of ‘dividend’ has been amended, and a new definition in Article 10 explicitly includes; income from distributions on certificates or participating units of an investment fund and their redemption, income from liquidation or partial liquidation of a company and income from the purchase or redemption of its own shares, by a company.
  • Withholding tax on interest payments, which is defined in Article 11, has been reduced. The maximum withholding tax that a Contracting State can levy, on outbound interest payments, when the beneficial owner is a resident of the  Contracting State, is 4%. In the previous version it was 5%.
  • Article 12 on royalty payments has been revised. New provisions include not only royalty payments but also payments for technical services. Such payments are now subject to the shared taxing right. The Resident State has the obligation to provide relief for the taxes suffered at the Source State. The Source State may tax payments for technical services at a maximum rate of 5%.
  • Income from an immovable property company, regulated by Article 13, was amended. The updated version details, that gains derived by a resident of a Contracting State, such as interests in a partnership or trust, or certificates or the participating units  of an investment fund, may be taxed in the other Contracting State if, during the 365 days preceding the sale or transfer of these shares or comparable interests, more than 50% of their value was derived directly or indirectly from immovable property situated in the other State.

The previous provision stipulated that if more than 50% of the value of shares directly or indirectly were derived from immovable property the capital gains from the sale of those shares could be taxed in the State where the property, owned by the company, was situated.

  • Article 16 dealing with director’s fees has been changed. The old rule stated that this type of income earned by a resident of a Contracting State could be taxed in the other Contracting State, where the company is resident. The new Article 16 provides that this type of income shall be taxed only by the Resident State. This change provides an exclusive taxing right in the State where the individual director is resident.

The new Article also expands on the definition of ‘director’, as a member of the board of directors and as a member of the supervisory board.

  • New Article 23 amends the method of elimination of double taxation. It now provides that if a Polish resident’s income is liable to tax in Malta, the amount  paid will be subject to a tax deduction in Poland.
  • Article 25 – Mutual Agreement Procedure has been changed. The amendment states that the competent authority will try to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the agreement. Any agreement reached shall be implemented notwithstanding  obligations under the domestic law of the Contracting States. 
  • Exchange of Information – Article 26, authorises the use of such information, received by a Contracting State for other purposes, provided that the competent authority of the supplying State authorises such use.

A new Article 26A has also been inserted which provides for the prevention of tax treaty abuse practices.

Date of Implementation

The changes will come into the force the first day of January of the year following the date on which the Protocol comes into force.

This is therefore likely to be January 2022.

Additional Information

For further information about Malta-Poland Double Tax Treaty please contact Jonathan Vassallo or Henno Kotze, at the Dixcart office in Malta: advice.malta@dixcart.com. Alternatively, please speak to your usual Dixcart contact.

Malta

Malta Initiative Moves Forward – A Shared Database of Ships Linked to Criminal Activity

Posted on | by Charlotte Clabon

Background

Crime-linked vessels are an unfortunate reality worldwide. The lack of information about vessels can result in countries flagging or re-flagging ships involved in criminal activities, or letting such vessels sail out of their ports unimpeded.

Main Concerns for Malta

Malta has had long-term concerns regarding contraband  linked to Italian organised crime as well as to Libyan militia groups.

The head of Malta’s sanction board Neville Aquilina, detailed in an International Maritime Organisation (IMO) Assembly “mechanisms for the full implementation of UN sanctions requirements are either too weak or inexistent”.

In addition, vessels which have been sanctioned in one country are able to sail to another jurisdiction, to obtain their license. This is possible because countries which de-flag vessels do not have the obligation of informing other countries about this and/or other actions taken.

International Database Proposal – A Shared Database of Ships Linked to Crime

In March 2020, in a meeting arranged by the IMO and the International Maritime Law Institute (IMLI), Malta proposed an idea to the EU to deal with this issue:

  • Malta suggested the idea of building a global database of vessels or companies, connected to illicit activities or subject to international sanctions, and for this database to be shared between countries, to help them make informed decisions.

The goal is to strengthen international maritime law, specifically, making it more difficult for criminals to obtain vessel licenses when they sail from one country to another, after their ship has been de-flagged for sanction violations in a previous country.

In addition, this new information about vessels worldwide will make it easier to carry out investigations. Currently these can take years to complete because of the lack of information available.

International Database Creation

Malta raised this idea again in 2021, during a follow-up event. In April 2021 the European Commission agreed to start working on a database across the EU, and to introduce it as soon as possible, in the forthcoming months.

Malta’s Standing

Located centrally in the middle of Europe and to the north of Africa, Malta is ranked sixth in terms of world ship registration and regards this new initiative as being extremely important.

Implementation Intentions

Even though the objective for the shared database of ships linked to crime is to be used by all of the IMO state members, the IMO has not, as yet, committed to a date to implement the database.

Dixcart will keep you updated.

Additional Information

For further information about the Malta flag please contact Jonathan Vassallo, at the Dixcart office in Malta: advice.malta@dixcart.com. Alternatively, please speak to your usual Dixcart contact.

Cyprus Holding Companies and The Advantages Offered Through Notional Interest Deduction (NID)

Posted on | by Charlotte Clabon

Background: Cyprus Companies

The reputation of Cyprus as an international financial centre has grown significantly over recent years. Cyprus is an attractive jurisdiction for trading and holding companies and offers a number of tax incentives.

Companies enjoy a 12.5% rate of tax on trading and a zero rate of capital gains tax. In addition Cyprus has over 50 double tax treaties to assist with international tax structuring.

Tax Residency

A company that is managed and controlled from Cyprus is considered to be tax resident in Cyprus.

What is Notional Interest Deduction and When Does it Apply?

Cyprus tax resident companies and Cyprus permanent establishments (PEs), of non-Cyprus tax resident companies, are entitled to a Notional Interest Deduction (NID), on the injection of new equity used to generate taxable income.

NID was introduced by Cyprus in 2015, to reduce discrepancies in the tax treatment of equity financing compared to debt financing, and to promote an incentive for capital investment in Cyprus. NID is deductible, in the same manner as interest expenses, but it does not trigger any accounting entries as it is a ‘notional’ deduction.

What Tax Advantages are Available Through the Use of Notional Interest Deduction?

NID is deducted from taxable income. It cannot exceed 80% of the taxable income, as calculated prior to Notional Interest Deduction, arising from the new equity.

  • A company could therefore achieve an effective tax rate as low as 2.50% (income tax rate 12.50% x 20%).

Initially, the NID rate was defined as the 10 year government bond yield, as at 31 December of the year preceding the tax year the NID is claimed, of the country in which the new equity was employed, plus a 3% premium. This was subject to a minimum rate equal to the yield of the 10 year Cyprus government bond plus a 3% premium.

  • Since January 1, 2020 the NID rate has been defined as the interest rate of the 10 year government bond yield of the country in which the new equity is invested, as published annually, plus a 5% premium. The interest rate of the Cyprus 10 year government bond will no longer be used as a general minimum rate. It is only deemed to be relevant, when the country in which the new equity is invested has not issued any government bonds, as of 31 December the year preceding the tax year the NID is claimed.

Additional Information Regarding the Taxation of Companies in Cyprus

The following sources of income are exempt from corporate income tax:

  • Dividend income.
  • Interest income, excluding income arising in the ordinary course of business, which is subject to corporation tax.
  • Foreign exchange gains (FX), with the exception of FX gains arising from trading in foreign currencies and related derivatives.
  • Gains arising from the disposal of securities.

Deductible expenses

All expenses incurred wholly and exclusively in the generation of income are deductible when calculating taxable income.

Additional Information

If you have any questions or would like additional information on this topic, please contact Robert Homem at the Dixcart office in Cyprus: advice.cyprus@dixcart.com.

St Kitts and Nevis Citizenship By Investment: Expansion of Eligible Properties – Need to Act Now

Posted on | by Charlotte Clabon

One of the oldest and most respected programmes of its kind, the St Kitts & Nevis Citizenship by Investment Programme grants qualified applicants instant visa-free access to over 150 countries.

EXCITING NEW Changes to The Approved Property Criteria!

  • It has been announced that until November 2022, the sale of private homes, under the St Kitts & Nevis Citizenship by Investment programme, has now been approved.   

This exciting change means that any private home with an appraisal value of $400,000 or more, is eligible for investors to apply for Citizenship (subject to certain criteria).

Therefore, for a limited period, the range of potential real estate options has never been broader!

If you would like to explore the range of new properties that are available, please contact John Mellor: advice.nevis@dixcart.com.

Approved Property Development: Further Details

  • The investment must be a minimum US$400,000, as detailed above, and the property must be held for a minimum of 5 years after the citizenship has been granted.

A registration fee is payable by the applicant and additional fees are required for the spouse, children under the age of 18 and additional family members over the age of 18. The addition of a sibling is US$40,000.

The Dixcart office in Nevis can help source management services for the property, which can be sold on after 5 years.

Additional Information and to Apply

To apply, please contact John Mellor in the Dixcart office in St Kitts & Nevis: advice.nevis@dixcart.com.

Applications must be handled by ‘Registered Authorised Persons’, such as Dixcart who are a licensed Service Provider for the St Kitts & Nevis Citizenship by Investment programme.