Category: Corporate Services

The Maltese tax regime has historically been based on a full imputation system, further enhanced by a network of over 70 Double Taxation Agreements (DTAs), and by the possibility to apply for unilateral tax relief for countries with whom a DTA is not in place. The corporate tax rate for a company incorporated in Malta is 35%. There are instances, however, in which the features of the Maltese tax system might be beneficial and lead to cost-effective and tax-efficient solutions for businesses.

We have previously written about the Consolidated Group Rules, which were added to the legislation in 2019, introducing the concept of fiscal unity and resulting in cash flow advantages where only the effective tax rate (5%/10%) must be paid, eliminating the requirement to pay the full 35% tax and wait for the refund for Malta-based companies; the Notional Interest Rate Deduction introduced in 2017 which encourages equity financing (providing a tax deductible expense on the value of the company equity) as opposed to debt financing, resulting in tax savings while at the same time stimulating investment and supporting entrepreneurship; the Participation Holding Exemption under which, in certain cases, dividends received from the subsidiary company are not subject to taxation in Malta from a shareholding as low as 5%.

In this article, we will delve into the Maltese Double-Tier (or Two-Tier) structure and the benefits for shareholders.

Tax Refund for Shareholders Resident Abroad

With regards to corporate taxation, non-Maltese resident shareholders can claim, upon the distribution of dividends, a tax refund of 6/7ths for active income and 5/7ths on passive income. This would bring the effective taxation to 5% in case of active income and to 10% in case of passive income.

The refund is to be claimed by the shareholders, who will receive the refund by the Maltese tax authorities, which are bound to pay the refund within a reasonable timeframe by a bank transfer to the shareholder anywhere in the world. For example, if a trading company generates an income of €100, the company will pay €35 as tax, while €65 will go to the shareholder as dividends. The shareholder would then receive a tax refund of €30 from the Maltese tax authorities, bringing the effective taxation to 5%.

The Two-Tier Structure

In this scenario, popularly referred to as the Maltese Double Tier Structure, there would be a structure whereby a Malta Holding company holds shares in another Maltese company, for instance, a trading company. By doing this, the tax refund is not received by the shareholder, but by the Holding company. The Holding company can then remit the full amount, consisting of the dividend income plus the tax refund, to the shareholders.

For example, if a trading company generates an income of €100, the company will pay €35 as tax, and €65 will go to the holding company as dividends. The holding company would then receive a tax refund of €30 from the Maltese tax authorities. After this, the Holding company may distribute €95 to the shareholder.

The Double-Tier structure is particularly effective when the Malta Company engages in trading activities, but can be applied also to investment, rental and Intellectual Property activities.

The Two-Tier Structure with Fiscal Unity – Cashflow Benefit Option

The Double-Tier structure can be created under the regime of fiscal unity. In this case, the ‘Group’ (Holding Company and Trading Company) would need to prepare consolidated financial statements and present a consolidated tax return to the Maltese Tax Authorities, and therefore only the effective tax rate will be charged. The advantages of this regime include simplified tax management, enhanced efficiency and significantly improved cash flow. For more information on the fiscal unity, please read this article on the Dixcart website: Malta Introduces Consolidated New Group Rules – Offering Cash Flow Advantages. It is important to underline that the fiscal unity regime is optional, and the decision is at the prerogative of the company.

Dixcart in Malta

The Dixcart office in Malta has a wealth of experience across financial services and offers legal and regulatory compliance insight. Our team of qualified Accountants and Lawyers are available to set up structures and help to manage them efficiently.

Additional Information

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

Switzerland is a friendly place to start a business, with many international companies having their headquarters in the country. Companies both large and small are attracted to Switzerland for its stability, the strength of its currency, and some of the lowest corporation taxes in Europe.

So, you have decided to start a business in Switzerland? You have a business plan and are ready to get started.

1. Legal Structure

Entrepreneurs can choose from several legal structures when setting up a business in Switzerland, including:

• Sole Proprietor: A business structure where a single individual owns and operates the business, assuming full personal liability for its obligations.
• Partnership: A legal form where two or more individuals share ownership and responsibility for a business, with options for general and limited partnerships.
• Limited Liability Company:  A legal business entity that combines elements of partnership and corporation, providing limited liability to its owners while maintaining operational flexibility.
• Branch: A business extension of a foreign company in Switzerland, operating as a dependant part of the parent company and subject to Swiss regulations.

Each structure has its advantages and implications for liability, taxation and governance, so it is crucial to select the most suitable option based on the nature and scale of the business.

2. Registration Process

The registration process varies depending on the chosen legal structure. However, in general, the following steps are involved:

1. Choose a business name and verify its availability.
2. Open a bank account with a Swiss bank to deposit the share capital.
3. Prepare the necessary documentation.
4. Founders Meeting with a Public Notary.
5. Register the business with the relevant commercial register and tax authorities.
6. Obtain any required permits or licenses based on the industry and activities of the business.

Once you have chosen the most appropriate legal structure and started the registration process, important next steps are to understand your accounting requirements and tax considerations.

3. Accounting and Reporting Requirements

Swiss companies are required to maintain and file accurate accounting records in accordance with established financial standards ensuring compliance with the regulatory requirements.

4. Tax Considerations

Switzerland offers a competitive tax environment for businesses, with varying rates between cantons. Key aspects of taxation include:

• Corporate tax: businesses are subject to federal, cantonal, and municipal taxes and it is essential to understand the tax implications based on the location and nature of the business activities.
• Value-Added Tax (VAT): Businesses with annual turnover exceeding CHF 100,000 or more a year must register for VAT and charge VAT on their goods and services. Value-added tax is a general tax levied on the distribution, import, export, and sale of a product or service by any company in Switzerland. 
• Double Taxation Treaties: Switzerland has double taxation treaties with numerous countries to avoid double taxation of income in multiple jurisdictions.

5. Employment Regulations

Switzerland’s employment laws are characterised by flexibility and employee protection. These considerations include:

• Employment Contracts: Written contracts outlining terms of employment, including wages, working hours and benefits are standard practice.
• Work Permits: Foreign nationals working in Switzerland may require work permits, which are subject to specific conditions depending on the individual’s nationality and qualifications.
• Minimum Wages: While Switzerland does not have a statutory minimum wage at the federal level, certain cantons and industries may have minimum wage regulations.

6. Compliance and Regulatory Matters

Switzerland has a well-established regulatory framework governing various aspects of the business operations, covering:

• Company Law: Compliance with Swiss company law, including corporate governance, shareholder rights, and disclosure obligations.
• Anti-Money Laundering Regulations: Implementation of AML compliance programmes to combat money laundering and terrorist obligations.
• Data Protection: Adherence to data protection regulations, ensuring privacy and security of personal data.
• Regulatory Authorities: Oversight by regulatory bodies specific to industries or activities, such as FINMA for financial institutions.

Advice and Additional Information

If you would like to know more about setting up a business in Switzerland or if you have any questions about how we can help you, please contact us for further information: advice.switzerland@dixcart.com

Dixcart has had an office in Switzerland for over twenty-five years and is well placed to provide advice regarding the establishment of companies here.

Understanding the nuances of corporate taxation in Portugal is crucial for effectively advising your international clientele or to understand your business as an entrepreneur. Below provides a snapshot of corporate tax implications in Portugal, however, engaging with a professional is advised, as it is likely that not only corporate tax requires consideration.

Taxation of Resident Companies

Generally, companies considered tax residents in Portugal face taxation on their worldwide income.

Standard Corporate Income Tax Rates

A flat Corporate Income Tax (CIT) rate of 20% is levied on the total taxable income of companies’ resident in mainland Portugal.

The Autonomous Region of Madeira and the Autonomous Region of the Azores benefit from a reduced standard CIT rate of 14.7%, which also applies to Permanent Establishments (PE’s) of foreign entities registered within these regions.

Summary of Key CIT Rates

The corporate income tax rates vary significantly and are detailed below:

	Portuguese Mainland Company	Madeira Company	International Business Centre of Madeira Company (for international activity)
First €50,000 of taxable income (small-medium enterprises)	16%	11.9%	5%
Taxable income above €50,000	20%	14.7%	5%

Note: The rate for companies within the International Business Centre of Madeira (IBC) are subject to specific substance requirements being met.

CIT Rates for Inland Territories (SMEs & Small Mid-Caps)

Taxable Income Bracket	Mainland Portugal Inland Territory	Autonomous Region of Azores Inland Territory	Autonomous Region of Madeira Inland Territory
First €50,000 of taxable income	12.5%	8.75%	8.75%
Taxable income above €50,000	20%	14.7%	14.7%

Note that these companies need to be located in specific territories and that there needs to be specific substance in place to substantiate the lower tax rate.

Surtaxes

Beyond the standard CIT rates, the following surtaxes may apply to corporate taxable income (before deducting loss carry forwards) as an additional tax charge:

• Local Surtax (Derrama): Up to 1.5% in certain municipalities, paid with the CIT return.
• State Surtax (Derrama Estadual): Applicable to commercial, industrial, and agricultural activities (resident and non-resident with PE), paid in three instalments:
  • 3% on profit between €1.5M and €7.5M.
  • 5% on profit between €7.5M and €35M.
  • 9% on profit exceeding €35M.
• Regional Surtax (Derrama Regional):
  • Madeira: 2.1% (€1.5M-€7.5M), 3.5% (€7.5M-€35M), 6.3% (>€35M).
  • Azores: 2.4% (€1.5M-€7.5M), 4% (€7.5M-€35M), 7.2% (>€35M).

Reach Out

By staying informed and engaging with an appropriate professional about a jurisdiction’s tax regulations can provide valuable guidance and support to operating a business in Portugal, particularly those involved in international activities or who are not from Portugal. Other taxes (such as VAT, social security on employees, among others) may apply and will need to be considered.

Dixcart Portugal provide a host of accounting, tax and consulting services. Reach out for more information at advice.portugal@dixcart.com.

Why Are Swiss Holding Companies So Popular?

Swiss holding companies are highly regarded for their strategic role in international business. Switzerland’s combination of political stability, legal certainty and an attractive tax framework creates a highly supportive environment for investment structures. These advantages make Swiss holding companies a preferred choice for many international investors.

Key Advantages:

1. Stability: Switzerland’s political neutrality, strong economy and robust legal system create a secure and predictable environment for business operations and international investments.
2. Attractive Fiscal Environment: The Swiss tax system promotes corporate growth, offering various incentives and reliefs available to qualifying entities, such as those outlined below.
3. Robust Infrastructure: Cities like Geneva and Zug are major centers for commodity trading and provide strong business support services and access to professionals like lawyers, bankers, and corporate advisors, including Dixcart Switzerland.
4. Strategic Location: Situated in the heart of Europe, Switzerland enables real-time communication with key markets in Europe, the US and Asia.
5. Skilled Workforce: Switzerland offers access to a highly educated, multilingual workforce, ideal to support seamless international operations.

Understanding the Role of a Swiss Holding Company

A Swiss holding company primarily exists to own and manage long-term shareholdings in other companies, either within Switzerland or abroad.

Key benefits include:

Tax Efficiency

• Participation Exemption: Swiss holding companies benefit from a participation exemption, which reduces or eliminates corporate income tax on qualifying dividends and capital gains. To qualify, the company must hold at least 10% of the subsidiary’s equity or a participation with a market value exceeding CHF 1 million, for at least one year.
• Interest Payments: Interest paid on loans from foreign shareholders may not be subject to Swiss withholding tax, subject to structuring.
• Extensive Double Tax Treaty Network: Switzerland has an extensive network of taxation treaties with over 100 countries, preventing double taxation and reducing withholding taxes on cross-border dividends, interest, and royalties. Under the EU-Switzerland Savings Tax Agreement, dividend distributions to EU parent companies may be exempt from Swiss withholding tax, provided the parent company holds at least 25% of the subsidiary for a minimum of two years.

Asset Protection and Wealth Management

Swiss holding companies play an important role in safeguarding assets and facilitating efficient transfer of wealth. They also benefit from access to Switzerland’s world-class private banking and investment services.

Flexible Corporate Structures

Swiss law allows for flexible corporate structures, accommodating various business needs. Holding companies can be established with minimal administrative requirements, and foreign investors can fully own Swiss companies, making it an accessible option for international clients.

Conclusion

Swiss holding companies offer a rare combination of tax advantages, political and economic stability, strategic location, and access to world-class financial services. These factors make them a preferred choice for businesses and individuals seeking a reliable and efficient structure for international investments management.

Additional Information

If you would like additional information regarding Swiss Holding Companies, please contact Christine Breitler at the Dixcart office in Switzerland: advice.switzerland@dixcart.com.

Background

Malta has the geographical advantage of being situated in the middle of the Mediterranean Sea, at a crossroads between Europe, North Africa and the Middle East. This island offers a fully developed open market economy, and has a hardworking and multilingual population (English is an official language of Malta). It also offers a corporate tax regime that in certain cases is extremely beneficial for shareholders.

Malta is one of a few ‘lucky’ countries where the weather is temperate all year round. The summer begins in May and conventionally ends in October, but even the “winter” weather is very comfortable, and the air temperature rarely drops below +12 ° C.

International Status of Malta

Factors contributing to and enhancing the international status of this jurisdiction include:

• Malta is a member of the EU and therefore has access to European Union Directives.
• Malta is a full Schengen Member state and has access to all the benefits that this brings.
• It is a Sovereign Independent State, enjoying political, economic and social stability.
• Malta has friendly relations with the majority of countries across the world through its policy of non-alignment.
• Companies operating in Malta are subject to a corporate tax rate of 35%. However, non-resident shareholders enjoy low effective rates, as Malta’s full imputation system of taxation allows generous unilateral relief and tax refunds.

Malta’s Full Imputation Method of Taxation

The unilateral relief and refund system provides a low effective Maltese tax rate of 5% for active income and 10% for passive income:

• Active income – in most instances non-resident shareholders can apply for a tax refund of 6/7ths of the tax paid by the company on the active profits used to pay a dividend. This results in an effective Maltese tax rate of 5% on active income.
• Passive income – in the case of passive interest and royalties, non-resident shareholders can apply for a tax refund of 5/7ths of the tax paid by the company on the passive income used to pay a dividend. This results in an effective Maltese tax rate of 10% on passive income.

We have discussed, in a recent article, the Two-Tier structure and the concept of fiscal unity, which would offer simplified tax management, enhanced efficiency and significantly improved cash flow.

What Other Tax Advantages are Available to Maltese Companies?

Other tax advantages are also available to companies established in Malta:

• No withholding tax on dividends, even if they payment is made to a non-European jurisdiction.
• Qualifying dividends and capital gains derived from a “participating holding” are, at the option of the taxpayer, exempt from Malta tax.
• Notional Interest Deduction (NID). NID is an innovative way in which Maltese companies can, in the correct circumstances, reduce their tax liabilities. This option is of greatest interest to companies with large equity balances. NID allows companies to deduct a notional interest amount based on the ‘risk’ capital of a company. Such companies will be able to claim a deduction against chargeable income, for NID deemed to be incurred on their equity capital. Previously in Malta, debt interest had been tax deductible, whilst dividends were not. Please see the following Article for additional information: Unlocking the Notional Interest Rate Deduction in Malta: Everything You Need to Know for Optimal Tax Planning
• Malta has approximately 70 Double Taxation Treaties in place. If there is no relevant double taxation treaty, then unilateral tax relief is available.

Other Attractive Factors for Maltese Companies

There are additional advantages available to companies established in Malta, depending on the specifics of the particular company and its employees. 

• Start-up funding is available for setting up operations in Malta. There is additional booster funding available if the company operates in the technology space.
• The regulator is approachable, and, on the basis of a solid business proposal, is happy to discuss setting up ‘sandbox environments’, to test new technologies
• Fast-track employment permits are available for third country nationals under the ‘Key Employee Initiative. The Malta ‘Key Employee Initiative is available to managerial and/or highly technical professionals with relevant qualifications or adequate experience relating to a specific job. Successful applicants receive a fast-track work/residence permit within five working days from the date of application, valid for one year. This can be renewed for a maximum period of three years.
• A special tax rate of 15% can be enjoyed by certain individuals employed in; Research & Development/Financial Services/Aviation/Online Gaming, under the Highly Skilled Programme.

Dixcart Corporate Services in Malta: Registration and Maintenance of Companies

Services available from the Dixcart office in Malta include:

• Company registration: preparation and submission of all necessary documents, obtaining permits, certificates and licenses.
• Opening bank accounts and interaction with banks on any matters.
• Corporate secretarial: documentation and reporting, and compliance with all legal requirements.
• Office services: rental of a workspace or an office, internet access, telephone and fax, office equipment, and assistance with correspondence, if required.
• Other services: bank account management, accounting services, assistance in employing foreign employees by the Maltese company.
• Change of jurisdiction: domiciliation of the company to Malta, and the use of Maltese companies in combination with other jurisdictions.

Additional Information

For further information about establishing a company in Malta, please contact Jonathan Vassallo or Clive Azzopardi, at the Dixcart office in Malta: advice.malta@dixcart.com. Alternatively, please speak to your usual Dixcart contact.

On 6 May 2025, the United Kingdom and India finalised a landmark Free Trade Agreement, marking a significant milestone in bilateral relations. This agreement, the UK’s most substantial post-Brexit trade deal, is projected to boost the UK economy by £4.8 billion annually by 2040.

Key Highlights of the Agreement

1. National Insurance Exemption for Indian Workers – Employers and Employees

A pivotal feature of the UK–India Free Trade Agreement is the three-year exemption from UK National Insurance Contributions (NICs) for both:

• Indian employees temporarily seconded to the UK; and
• Their Indian employers, provided the secondment is part of an intra-company transfer.

This means that neither the employer nor the employee will be required to pay UK NICs during the qualifying secondment period, provided they continue contributing to India’s social security system. The arrangement is reciprocal, applying equally to UK employees seconded to India.

The exemption only applies to secondments involving employers with operations in both countries. It does not extend to Indian nationals employed solely by UK-based entities.

Implications:

• Cost Efficiency: The combined saving of employer and employee NICs can reduce total employment costs by up to 20%, improving competitiveness and cash flow.
• Global Mobility Planning: Multinational companies can strategically deploy staff between the UK and India without dual social security contributions.
• HR Compliance: Businesses must ensure the secondment arrangement meets the definition of an intra-group transfer and is time-limited to three years.

2. Tariff Reductions and Market Access

The agreement eliminates tariffs on 90% of UK exports to India, including sectors like whisky, gin, cosmetics, and food products . Conversely, 99% of Indian exports, such as textiles, food, and jewellery, will face no import duty in the UK.

Opportunities:

• Export Expansion: Indian businesses can capitalise on duty-free access to the UK market, particularly in textiles and jewellery.
• Investment Prospects: The reduction in tariffs opens avenues for joint ventures and partnerships in key sectors.

3. Enhanced Professional Mobility

The FTA streamlines visa procedures and employment laws, facilitating the movement of Indian professionals to the UK. This includes contractual service suppliers, business visitors, investors, and independent professionals such as yoga instructors, musicians, and chefs.

Considerations:

• Talent Deployment: Businesses can leverage this provision to deploy skilled professionals in the UK market efficiently.
• Compliance: Ensure adherence to the UK’s qualification and experience requirements for professionals.

4. Exclusion of Legal Services

Notably, the legal services sector is excluded from the agreement, with the Law Society of England and Wales expressing disappointment over this omission. This exclusion is seen as a missed opportunity for both economies.

Strategic Implications for Indian HNWIs and Businesses

Tax Planning and Corporate Structuring

The NI exemption offers a strategic advantage for Indian businesses with UK operations. By reducing employment costs, companies can reallocate resources to other growth areas.  There is also a benefit of reduced employee NI costs for the  individual giving then a higher net income than otherwise. However, it is crucial to evaluate the long-term tax implications and ensure compliance with both UK  and Indian tax regulations.

Investment and Expansion Opportunities

The tariff reductions and improved market access present lucrative opportunities for Indian investors and businesses to expand their footprint in the UK. Sectors such as fashion, textiles, and jewellery are poised for growth, given the elimination of import duties.

Professional Mobility and Talent Acquisition

The streamlined visa processes facilitate the movement of Indian professionals, enabling businesses to tap into the UK market’s talent pool and meet operational needs effectively.

Conclusion

The UK–India Free Trade Agreement signifies a new era of economic collaboration between the two nations. For Indian individuals and businesses, this agreement opens doors to strategic tax planning, market expansion, and talent mobility. Engaging with experienced tax advisors and legal experts will be essential to navigate the complexities and maximise the benefits of this landmark deal.

For more information, please contact us: advice.uk@dixcart.com.

Malta is one of the most attractive destinations for establishing holding companies dedicated to managing intellectual property (IP), thanks to its combination of favourable tax benefits, a strong legal framework, a network of over 70 Double Taxation Agreements (DTAs) and direct access to the European single market. In 2025, setting up a company in Malta to manage IP is a smart choice, as the country’s tax system offers significant incentives that allow for tax optimisation, facilitate profit repatriation, and protect intangible assets effectively.

The Maltese Corporate Tax Regime

Malta’s full imputation tax regime is a key draw for IP businesses, offering a tax refund mechanism to non-resident shareholders that effectively reduces the  corporate tax rate to 5%. This is combined with the absence of any withholding tax on dividends, royalties, or interest paid to non-residents.

Benefits in Malta For IP Holding Companies

These factors make Malta one of the most tax-efficient jurisdictions for holding intellectual property, benefiting both local and international investors. Royalties from active licensing activities, which are initially taxed at 35%, can be reduced to just 5% under this regime in case of multiple royalties’ streams. Effective taxation would be 10% in case of only one royalties’ stream.

Another significant advantage is Malta’s exemption from taxation on royalties derived from patents or copyrights, whether developed in Malta or abroad. Additionally, profits from these royalties can be distributed as tax-free dividends to shareholders, optimising returns on investment.

When the IP is transferred within a group or from an individual to a company, it can be revalued at fair market value (FMV) for tax purposes. This increases the asset’s base for amortisation, reducing taxable income. Malta allows companies to amortise the stepped-up value of IP over a minimum period of three years, leading to significant tax deductions. With a properly structured transfer, the capital gain arising from the step-up may qualify for participation exemption (in certain cases) or be taxed at the corporate rate of 35%.

UE Membership

Furthermore, the EU Interest and Royalties Directive allows for tax-free royalty payments between associated companies within the EU, making it even easier to repatriate profits. Malta, as a member of the European Union, is fully aligned with European regulations, allowing it to offer excellent protection for intellectual property under European legal frameworks. Thanks to its EU membership, IP rights such as trademarks, patents, and designs can be registered both through the national system and the European Union Intellectual Property Office (EUIPO). This provides access to a market of over 450 million people and ensures strong protection across the region. On a global scale, Malta is also a signatory of key international treaties such as the Paris Convention, the Berne Convention, and the TRIPS Agreement (Agreement on Trade-Related Aspects of Intellectual Property Rights), ensuring that IP assets are strongly protected worldwide.

Registration

The process of registering and managing IP in Malta is relatively straightforward and affordable compared to other European countries. Registration fees are lower, and the annual administrative costs of maintaining a holding company in Malta are also competitive, enabling businesses to keep their operational costs low and achieve higher profitability. For IP assets, trademarks can be registered through the Malta Trade Department or the EUIPO, while patents are handled through the Malta Intellectual Property Office or the European Patent Office (EPO). These registration processes allow companies to secure ownership and control over their intangible assets, taking advantage of a stable and reliable legal environment.

Additional Information

For additional information, please speak to Jonathan Vassallo at the Dixcart office in Malta: advice.malta@dixcart.com or get in touch with your usual Dixcart contact.

Our team at the Dixcart office in Malta can assist you with the establishment of an IP Holding Company in Malta and manage all the relative accounting, compliance and legal-related sides of the business.

Register of Overseas Entities Background

The Register of Overseas Entities, effective from 1 August 2022 under the Economic Crime (Transparency and Enforcement) Act 2022, requires overseas companies and other non-human entities owning property in the UK to register with Companies House and disclose their beneficial owners or managing officers.

Most of the information given to Companies House about overseas entities, beneficial owners and managing officers, will be publicly available on the Register of Overseas Entities. This is intended to increase transparency, allowing law enforcement agencies to investigate suspicious wealth more effectively. 

Changes to Trust Data Access on the Register of Overseas Entities

Over the coming year, there will be changes to the public visibility of data held on the Register of Overseas Entities:

Protection of Trust Data (from 28 February 2025)

Most data relating to Trusts must be provided to the authorities but historically, it has not been publicly visible. However, this will become available on request (see below).

From 28 February 2025, you can apply to protect your Trust data from public availability if you meet the necessary criteria. You can apply to protect your details (or anyone that lives with you) if you are at risk of harm or intimidation if your information is available to the public. You cannot request protection just because you wish to keep information confidential and there must be a genuine risk of violence or intimidation.

Eligible Trust members who may apply for protection include beneficiaries, settlors, grantors, and interested parties.

You can also apply if you have the authority to act on behalf of a Trust member who is a minor (aged 17 and under) or lacks capacity as defined in Section 2 of the Mental Capacity Act 2005 You will need to provide evidence in this case.

Read more about the criteria and how to apply for protection on GOV.​UK and you can also request a paper form to apply for protection.

You’ll need to pay £100 per application. This will be refunded if your application is rejected.

Public Access to Trust Data (from 31 August 2025)

Trust data on the Register of Overseas Entities will be available on request from anyone that applies to the Registrar, this provision comes into force 31 August 2025.

• Following an application, Companies House may share information that is held on the register with third parties.
• Requests must include applicant details and purpose – this must contain applicant’s name, contact details, job title/details, name of the overseas entity and OE number and/or name of the trust.
• A legitimate interest test applies for minors or multiple Trusts—only granted for investigations into money laundering, terrorist financing, tax evasion, or sanctions avoidance.
• Companies House may impose restrictions on disclosed information – such as restricting the use of the information or further disclosures.
• A request may be refused on a number of grounds, including where the disclosure may prejudice an ongoing criminal investigation, it may adversely affect national security or where the Trust is a pension scheme.

Keeping Register Information Updated

• Entities must ensure their Trust data is accurate and update it in their annual statement if necessary.

Home Address

You can also apply to Companies House to remove your home address (usual residential address) if it is shown on the register. In order to remove your home address, you need to offer a replacement principal office or service address.

Additional information

If you require any addition information regarding or assistance with a registration or filing an update statement, please contact the Dixcart office in the UK: advice.uk@dixcart.com.

More information can also be found within our article: UK Register of Overseas Entities and Update Statements.

Introduction

An increasing number of individuals worldwide now hold investment portfolios, yet many overlook the present and future tax implications of their investments. In today’s dynamic global economy, safeguarding your assets in a stable, advantageous jurisdiction has become more important than ever.

Why use a Cyprus Company?

If you are seeking an optimal jurisdiction for structuring your investments, Cyprus offers a compelling solution. With a straightforward, stable, and proven fiscal framework, Cyprus provides a highly attractive tax regime for managing portfolio investments, making it an ideal location for establishing a portfolio holding company.

In a climate of heightened transparency and the negative associations tied to traditional offshore jurisdictions, investors increasingly prefer structuring their portfolios through EU-based entities. Cyprus stands out as a prime choice, offering numerous advantages:

• EU and Eurozone Membership: Cyprus benefits from the economic stability and regulatory alignment of the EU and Eurozone.
• Attractive Tax Regime: One of the most competitive tax systems in Europe.
• Established Financial Centre: Cyprus boasts a reputable financial infrastructure with a long-standing history.
• Qualified Professionals: Access to a vast pool of experienced professionals and business service providers.
• International Recognition: Cyprus is a whitelisted jurisdiction acknowledged by global regulatory bodies.
• Cost Efficiency: Lower maintenance costs compared to other EU jurisdictions.
• Strategic Location: Situated at the crossroads of Europe, Asia, and Africa.

A further advantage of using a Cyprus company for portfolio holdings is the flexibility to open bank accounts, engage brokers, and work with investment managers from any jurisdiction. Many individuals successfully utilise Swiss and other EU banks for their Cyprus companies.

How are Portfolio Profits Taxed in Cyprus?

• Dividend Income: Dividend income received by a Cyprus company from financial instruments is generally tax-exempt.
• Capital Gains and Trading Profits: Profits from the disposal of shares and other qualifying financial instruments are generally exempt from Cyprus taxation.
• Interest Income:
  • Active Interest: Interest earned from active sources is taxed at a rate of 12.5% on net profits.
  • Passive Interest: Interest from passive sources is not subject to income tax but instead taxed under the Special Defence Contribution (SDC) tax at a rate of 17% on the gross amount.
• Withholding Tax:
  • Inward Receipts: Cyprus benefits from over 60 double tax treaties as well as the EU Parent-Subsidiary Directive. As a result, taxes withheld in the country of origin are often applied at a very favourable rate.
  • Outgoing Payments: Provided that the recipient (whether an individual or a corporate entity) is tax resident in an OECD-compliant jurisdiction, there are generally no withholding taxes (WHT) on distributions from Cyprus to shareholders.

All companies that wish to make the most of the above benefits must be considered tax resident in Cyprus. In order to be considered tax resident a company must have sufficient economic substance in Cyprus.

How Can Dixcart Help You?

With over 50 years of experience in the sector, we have a wealth of knowledge in assisting individuals, families and corporates establish fully bespoke, compliant solutions. Our highly qualified team offer in-depth expert knowledge of the local regulatory framework, supported by our international network of offices, to help us find the ideal solution for you.

We provide a full suite of support services including incorporation, accounting, company secretarial, compliance, and other day-to-day support.

We are also not affiliated with any single bank, investment manager, or fund adviser. Instead, we maintain a diverse network of connections, enabling us to match you with the professional best suited to your unique requirements. This approach ensures impartiality and allows for the selection of the most appropriate third-party support, free from conflicts of interest.

If you are interested in establishing a holding company to manage your investment portfolio, please contact us. We would be delighted to answer any questions you may have and assist in creating the optimal structure for your needs. please contact us advice.cyprus@dixcart.com for more information.

The data contained within this Information Note is for general information only. No responsibility can be accepted for inaccuracies. Readers are also advised that the law and practice may change from time to time.

Portugal has emerged as an ideal destination for entrepreneurs and businesses seeking a stable, business-friendly environment within the European Union. With its strategic location, attractive tax regime, and vibrant economy, Portugal offers numerous opportunities for growth. If you are starting from scratch or considering re-domiciliation, this guide will walk you through the essential steps to establish your business in Portugal.  

1. Incorporation: Starting Fresh or Redomiciling

You have two primary options for establishing your business in Portugal:

• Incorporation: This involves creating a new Portuguese company, adhering to all local legal and regulatory requirements. It is the most common approach for businesses entering the Portuguese market.  
• Re-domiciliation: This process involves transferring an existing company’s legal domicile from another jurisdiction (e.g. France) to Portugal. This can help companies benefit from Portugal’s tax advantages and EU membership. However, it requires careful legal and tax planning to ensure compliance with both the original and new jurisdiction.

2. The Company Incorporation Process

The process of incorporating a company in Portugal generally involves these steps:

• Choosing a Company Structure: The most common types are:
  • Sociedade por Quotas (Lda.): A limited liability company, suitable for small to medium-sized enterprises.
  • Sociedade Anónima (SA): A public limited company, typically used for larger businesses.
  • Read here for more information on company structures in Portugal.
• Obtaining a Company Name Approval: You must register your chosen company name with the National Registry of Legal Persons (RNPC – Registo Nacional de Pessoas Colectivas). Other than confirming uniqueness, it ensures the company’s name complies with Portuguese legal requirements.
• Drafting the Company Statutes: These documents outline the company’s structure, objectives, and operational procedures – essential for establishing a clear and legally sound foundation for the company’s operations, governance, and roles and responsibilities of shareholder and directors. This serves as the company’s internal governance guide and is required for the registration of the company at the commercial registry.
• Obtaining a Tax Identification Number: The Portuguese tax system necessitates two types of tax identification numbers – namely:
  • NIPC (Número de Identificação de Pessoa Colectiva), the corporate tax number, is automatically assigned upon approval of the company’s name. This enables the company to fulfil tax obligations, engage in legal and financial transactions (such as opening bank accounts), and operate legally within Portugal.
  • NIF (Número de Identificação Fiscal), individual’s tax number, for individuals associated with the company, including directors and shareholders. This NIF is for their individual tax liabilities and any financial dealings related to the company.
• Opening a Bank Account: Essential for depositing the company’s share capital and managing financial transactions. Although it is not a prerequisite to have a Portuguese bank account, a bank account in Portugal is beneficial to transact with the Portuguese tax authorities (e.g. receive refunds from the tax authorities, for payment of employment social security amounts, etc.).
• Registering the Company at the Commercial Registry: This formalises the company’s existence and grants the company its legal personality. A registration fee is payable.
• Registering the Company with Social Security: Portuguese companies are required to register for social security (whether they have employees or not) – for which it will receive a unique social security registration number. This ensures, among others, compliance with labour laws.
• Obtaining Necessary Licenses and Permits: Companies may be required to obtain specific licenses or permits to operate in Portugal or the EU, depending on the scope of business activities and sector-specific requirements.

3. Shareholder Registry of Beneficial Owners and Public Access

Company ownership information in Portugal is generally public. The Commercial Registry discloses shareholder details, for limited liability companies. However, the Central Register of Beneficial Owners (RCBE) is needed to identify UBOs (Ultimate Beneficial Owners) with significant ownership (over 25% ownership or control), although searches are by company name only. Listed companies also report ownership changes through the CMVM (Comissão do Mercado de Valores Mobiliários) – the Portuguese Securities Market Commission. Despite these registries, identifying the true UBO can be difficult with complex structures.

4. Tax Rates and Considerations

• Portugal’s tax regime is a significant draw for businesses. Key aspects include:  
  • Portugal Mainland: The standard rate is 20%, with reduced rates for small andmedium-sized enterprises (SMEs) of 16% on the first €50,000 of net taxable income.
  • Autonomous Region of Madeira: The standard rate is 14.7%, with reduced rates for small and medium-sized enterprises (SMEs) of 11.9% on the first €50,000 of net taxable income.
    • If the company is involved in international activities, a 5% rate may apply through the Madeira International Business Centre (MIBC) – see here.
  • Value Added Tax (IVA): Standard rates are 23% in mainland Portugal, with reduced rates for certain goods and services. Reduced rates apply in Madeira and the Azores.
  • Non-Habitual Resident (NHR) Regime: Offers significant tax benefits for individuals (such as employees, directors, and shareholders tax resident in Portugal who qualify), including potential tax exemptions on foreign-sourced income. See here for more information.

5. Obligations to Shareholders and Directors

• Shareholders: Are entitled to dividends and have voting rights. They are also liable for the company’s debts up to their share capital.  
• Directors: Are responsible for managing the company’s affairs, complying with legal obligations, and acting in the best interests of the company. They have fiduciary duties and can be held liable for breaches of these duties. Directors are required to act with reasonable skill and diligence.

6. Opening a Bank Account

Without a bank account, a corporate entity may have no use. Portuguese banks and authorities have strict KYC (‘Know-Your-Client’) requirements to prevent money laundering and terrorist financing. Expect to provide detailed information about your company’s ownership structure, business activities, and shareholder’s source of funds.

The following may be required as a starting point:

• Company incorporation documents as detailed above
• NIPC (company’s registration and tax number) of the company
• Identification documents for directors and shareholders
• Proof of address (the company’s individual shareholders)
• Source of funds and wealth of shareholders and/or UBO

Although bank accounts may be opened remotely, it may be faster and more convenient to open in person.

7. Ensuring Company Substance

Demonstrating economic substance is critical for tax compliance in Portugal. Companies must maintain genuine economic activities and a physical presence within the country. Furthermore, to qualify for the 5% corporate income tax rate in Madeira’s International Business Centre, companies must meet specific substance requirements.

8. Reasons to Incorporate in Portugal

Lastly, various businesses have recently incorporated or redomiciled to Portugal. The reasons are vast and different, many of which have decided based on the following factors:

• EU Membership: Access to the European single market to conduct business.
• Stable Political and Economic Environment: Provides a secure base for business operations.
• Strategic Location: A gateway to Europe, Africa, and South America.
• Network of Double Taxation Agreements: Portugal has almost 80 double taxation agreements – some of which are unique like the agreement between Portugal and Angola. Click here for more information on double taxation agreements.
• Skilled Workforce: A growing pool of talent that can speak several languages, including English.
• Quality of Life: A desirable location for professionals and families.  
• Growing Tech Hub: Lisbon and other cities are attracting tech companies and startups. Read here for more information.

Visa routes: Various visa options are available, including the golden visa. Refer here for more details.

Conclusion

Establishing a business in Portugal requires careful planning and adherence to local requirements. However, the potential rewards are significant. By understanding the incorporation process, tax implications, and regulatory obligations, you can successfully launch and grow your business in this dynamic and promising market. It is highly recommended to seek professional advice to navigate the complexities of Portugal which may be different to the jurisdiction you are accustomed to.

Please contact advice.portugal@dixcart.com for a free initial consultation.