Cyprus – Attractive Lifestyle and Tax Benefits

Cyprus Lifestyle and Tax Benefits

Why choose Cyprus for relocation purposes?

Surrounded by the bright blue waters of the Mediterranean Sea, Cyprus has always been an enticing location for high-net-worth individuals considering relocation. It is a member of the EU and therefore well positioned for those who seek global mobility and ease of travel across Europe, as well as the Middle East and Africa.

English is widely spoken in Cyprus, having been part of the Roman Empire and a British colony for many years, however traditions run deep through the island’s villages, with each enjoying a variety of cultural influences to share with newcomers.

Cyprus has a Mediterranean climate. Whilst small, the island is an archaeological and natural haven, with stunning seaside villages and beaches. It is also home to a large community of expats who have relocated to Cyprus to enjoy the benefits that the island, and the tax regime offers.

Cyprus offers the following lifestyle benefits:

  • A Mediterranean lifestyle and peaceful, friendly community
  • A good work-life balance
  • Excellent transport links
  • A diverse range of amenities
  • Low cost of living
  • Excellent private and state healthcare sectors
  • A large expat community
  • A high quality of education, there is the option for private education (English curriculum) or public education, as well as several international Universities located on the island
  • Attractive tax benefits.

Cyprus Offers a Range of Interesting Tax Incentives for Individuals

Many high-net-worth individuals relocate to Cyprus due to its advantageous non-domicile tax regime, whereby individuals who were not previously tax resident can apply for non-domicile status.

Cypriot non-domiciles benefit from a zero rate of tax on; interest, dividends, and capital gains (apart from capital gains derived from the sale of immovable property in Cyprus), and capital sums received from pension, provident and insurance funds.

These zero tax benefits are enjoyed even if the income has a Cyprus source or is remitted to Cyprus. There are several other tax advantages, including a low rate of tax on foreign pensions, and there are no wealth or inheritance taxes in Cyprus.

Options for Relocating: Permanent Residence and Temporary Residence Permits

Individuals wishing to move to Cyprus can apply for a Permanent Residence Permit which is useful as a means to ease travel to EU countries and organise business activities in Europe.

Applicants must make an investment of at least €300,000 in one of the investment categories required under the programme, and prove they have an annual income of at least €30,000 (which can be from pensions, overseas employment, interest on fixed deposits, or rental income from abroad). If they choose to reside in Cyprus for seven years, in any ten-calendar year period, they may be eligible to apply for Cyprus citizenship by naturalisation.

Alternatively, a temporary residence permit can be obtained by establishing a foreign investment company (FIC). Through this kind of international company, work permits can be obtained for relevant employees, and residence permits for them and family members. Another key advantage is, again, that after residing for seven years in Cyprus, within any ten-calendar year period, third country nationals can apply for Cyprus citizenship.

Moving to Cyprus to take up Employment

It is common for high-net-worth individuals to relocate to Cyprus for employment purposes. If the Permanent Residence Permit is not the right route for you and/or your family, Cyprus offers several alternate ways to live and work in Cyprus:

  • Business Facilitation Unit: visas for highly skilled third country nationals – the Ministry of Finance announced in 2022, that they are introducing the Business Facilitation Unit to assist highly skilled third country employees with a minimum gross salary of €2,500 per month, to gain work permits in Cyprus. These permits will last up to three years.
  • Digital Nomad visa: non-EU nationals who are self-employed, salaried, or on a freelance basis can apply for the right to live and work in Cyprus remotely, for up to one year. The visa can be renewed for another two years.

Why Relocate to Cyprus for Work?

Personal taxation benefits:

  • A tax exemption, of 50% of employment income, is available to an individual employed in Cyprus who was resident outside of Cyprus before he/she commenced employment in Cyprus. The exemption applies for a period of seventeen years starting from the first year of employment in Cyprus, provided that employment income exceeds €55,000 per year.
  • Cyprus has more than 65 tax treaties that provide for zero or reduced withholding tax rates on; dividends, interest, royalties, and pensions received from abroad. In addition lump sums received as a retirement gratuity, are exempt from tax.
  • A Cypriot tax resident receiving pension income from abroad, can choose to be taxed at a flat rate of 5%, on amounts exceeding €3,420 per year.

Starting a Business in Cyprus as a Means of Relocation

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.

In order to encourage new businesses to the island, Cyprus offers two temporary visa routes as a means for individuals to live and work in Cyprus:

  • Establishing a Cyprus Foreign Investment Company (FIC): individuals can establish an international company which can employ non-EU nationals in Cyprus. Such a company can obtain work permits for relevant employees and residence permits for them and their family members. A key advantage is that after seven years, third country nationals can apply for Cyprus Citizenship.
  • Establishment of a small and medium sized Innovative Enterprise (Start-up visa): this scheme allows entrepreneurs (individuals or a team), from countries outside the EU and outside the EEA, to enter, reside and work in Cyprus in order to; establish, operate, and develop a start-up business. This visa is available for one year, with the option to renew for another year.

Corporate Tax Benefits:

  • Cypriot companies enjoy a 12.5% rate of tax on trading, and a zero rate of capital gains tax. In addition, 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 is deducted from taxable income. It cannot exceed 80% of the taxable income, as calculated prior to the Notional Interest Deduction, arising from the new equity. A company could achieve an effective tax rate as low as 2.50% (income tax rate 12.50% x 20%).

Get in Touch

For additional information about the attractive tax regime for individuals moving to  Cyprus, or information regarding relocating there, please contact: advice.cyprus@dixcart.com.

Movement of Millionaires During 2022

According to New World Wealth who compiled the data for the Henley Global Citizens Report, a projected 88,000 of the world’s millionaires will move to a new country by the end of the year.

High-net-worth individuals (HNWIs) with a net worth of over US$1 million are extremely mobile following the Covid-19 pandemic, as well as the current war in Ukraine which is having global repercussions. Due to the lockdown and travel restrictions from Covid-19, there are no specific reports for 2020 and 2021 but as restrictions have now eased, momentum is gaining as relocation has become front of mind for many of the ultra-rich.

It will come as no surprise that Russia and Ukraine are projected to see some of the biggest emigration numbers, by the end of 2022. Andrew Amoils, the head of research at New World Wealth stated in the report that “Russia [is] haemorrhaging millionaires […] Affluent individuals have been emigrating from Russia in steadily rising numbers every year over the past decade, an early warning sign of the current problems the country is facing”. Russia is projected to see 15% of their HNWIs moving (projected 15,000).

However, it is Ukraine that is expected to suffer the greatest loss of HNWIs as a proportion of its population – a huge 42% of its HNWIs, could leave by the end of 2022; a predicted net loss of 2,800 millionaires.

China and India are also predicted to see their millionaire populations relocate. General wealth growth in China has been slowly declining in the past few years, which could lead to China seeing its most damaging year yet.

India on the other hand is not so concerning. Predicted figures are suggesting that India will see approximately 8,000 HNWIs migrate during 2022, however there is also a suggestion that those who have relocated in the past, are returning. In the next few years, we would not be surprised if the HNWI population in India rises substantially, which will then make it one of the biggest growing wealth markets at that time.

The UAE

During 2022, the UAE is expected to draw in the largest inflow of HNWIs, with approximately 4,000 millionaires from; Russia, India, Africa, and the Middle East moving to the country. The UAE has been known as a ‘millionaire magnet’ for many years; it has a robust international business hub, sits at the top amongst the world’s most competitive tax systems, and offers a luxury lifestyle from education, leisure activities, shopping, and hospitality, to its top-end real estate sector. With the UAE predicted to surpass the US this year, the US is rapidly losing its appeal as a haven for the world’s wealthiest.

Australia

In second place sits Australia – approximately 3,500 HNWIs will move to Oz before the end of 2022 (and according to the New World Wealth, 80,000 millionaires have already relocated in the last two decades). It is one of the largest countries in the world, rich in natural resources and fertile land, and has a thriving economy.

Singapore

Singapore is a favoured location, mainly for the rest of Asia. Emerging as Asia’s top wealth management centre, this makes sense. A net inflow of approximately 2,800 HNWIs is expected to find a home in this prosperous country.

Israel

Israel sits closely behind, with large numbers of HNWIs from the UK, France and Russia set to move there; approximately 2,500 during the year.

Switzerland

But it is Switzerland we are keeping our eye on. Even though Switzerland is not part of the EU, it is within the Schengen area, and has always been an elite jurisdiction in which to settle down. Switzerland is projected to attract a net inflow of around 2,200 in 2022.

It has always featured amongst the top most attractive countries for high-net-worth individuals to live, being one of the world’s wealthiest countries and known for its impartiality and neutrality. In 2021 Geneva was listed as one of the wealthiest cities in the world with the total wealth held in the city amounting to US$875 billion.

Portugal

A consistent favourite, fuelled by the ‘Golden visa’ of Golden visas. Over the last decade, Portugal has seen HNWIs, wealthy entrepreneurs and ultra-rich investors from around the globe, predominantly from Turkey, South Africa, and South America, but also most recently from the US, relocate to its sunny shores. With the current hype around digital nomadism and the D7 visa, the younger generation of HNW families are setting up shop in Lisbon. An expected inflow of 1,300 HNWIs is expected in Portugal in 2022.

Greece

More and more HNWIs are relocating to Greece and applying for its Golden visa programme, with millionaires from Turkey, Russia, Ukraine, and China all favouriting the country. Greece is expected to see around 1,200 HNWIs apply in 2022. Dixcart has already seen interest, especially around the opportunities that are presented by obtaining a Greek residence permit but becoming tax resident in Cyprus and benefiting from the Cypriot non-dom tax regime.

Malta

Whilst just outside the top 10 list of countries gaining millionaires in 2022, Malta still has an important spot. Approximately 300 millionaires are expected to move to Malta in 2022, joining at least 2 billionaires already registered on the island.

In terms of wealth growth, the island currently has one of the fastest growing markets, with its strong economic performance in recent years being driven by its shift towards fast-growing services such as; finance, e-gaming and tourism, and its citizenship by naturalisation programme which has brought substantial new wealth to the island.

Summary

“Countries that draw wealthy individuals and families to migrate to their shores tend to be robust, with low crime rates, competitive tax rates, and attractive business opportunities,” Amoils has stated.

Dixcart Domiciles offers specialist advice regarding various residence programmes around the world. 

We can help you discover the different countries around the world that offer attractive residence and/or citizenship programmes and those that might suit you and your family best, and provide advice on a number of tax efficient solutions that might be available.

Get in touch

If you are considering relocating and would like to speak to an adviser to find out which programme and/or country best suits you and your family’s needs, please contact us: advice@dixcart-domiciles.com.

Why is the Isle of Man a Jurisdiction of Choice

In this short article we cover some of the most attractive reasons for individuals and companies to setup or move to the Isle of Man. We’ll be looking at:

But before getting into the benefits, it might be helpful to tell you a bit more about the island and its background.

A Short Modern-Day History of the Isle of Man

During the Victorian era, the Isle of Man represented an opportunity for British families to escape to their very own Treasure Island – only, with somewhat less pirates than Robert Louis Stevenson imagined. The development of key transport links such as regular steamship crossings, on-island steam engines and streetcars etc. made navigating to the jewel of the Irish Sea all the more attractive.

By the turn of the 20th century the Isle of Man had become a thriving tourist destination, sold in the posters of days gone by as ‘Pleasure Island’ and a place to go ‘For Happy Holidays’. It is not hard to imagine why the idyllic island, with its rolling hills, sandy beaches and world class entertainment, represented a first choice for those looking to escape the hustle and bustle of a modernising Britain. The Isle of Man provided a convenient, exciting, safe and rewarding place for those who ‘do like to be beside the seaside’.

However, during the second half of the 20th century, the Isle of Man simply couldn’t compete with the draw of low cost excursions to the continent and beyond. Thus, the island’s tourism sector declined. That is, save for the (semi)constant that has persisted (World Wars or COVID-19 permitting) – The Isle of Man TT Races – one of the world’s oldest and most prestigious motorcycle road racing events.

Today, the TT Races take place over multiple laps of an approx. 37 mile course and have run for well over a century; the current fastest average speed over the 37 miles is over 135mph and reaches a top speed of almost 200mph. To give an idea of scale, the Island’s resident population is approximately 85k, and in 2019 46,174 visitors came for the TT Races.

In the latter part of the 20th century to this day, the Island has developed a flourishing financial services sector – delivering professional services to clients and advisers across the world. This has been made possible by the island’s self-governing status as a crown dependency – setting its own legal and tax regime.

In more recent years, the Island has pivoted again to develop beyond financial and professional services, with strong engineering, telecoms and software development, e-gaming and digital currency sectors, and more besides.

Why do Business on the Isle of Man?

A truly business-friendly government, ultra-modern telecoms services, transport links to all major UK and Irish business centres and very attractive rates of taxation, make the Isle of Man an ideal destination for all businesses and professionals alike.

Businesses can benefit from Corporate rates such as:

  • Most types of business are taxed @ 0%
  • Banking business taxed @ 10%
  • Retail businesses with profits of £500,000+ are taxed @ 10%
  • Income derived from Isle of Man land/property is taxed @ 20%
  • No withholding tax on most dividend and interest payments

In addition to the obvious pecuniary benefits, the island also has a deep pool of well-educated expert workers, fantastic grants from the government to both encourage new businesses and provide vocational training and many working groups and associations in direct contact with local government.

Where relocating to the island is not physically possible, there are various options available to businesses wishing to be established on the Isle of Man and avail of the local tax and legal environment. Such activity requires qualified tax advice and the assistance of a Trust and Corporate Service Provider, such as Dixcart. Please feel free to get in touch to find out more in this regard.

Why you should move to the Isle of Man?

For individuals seeking to immigrate to the Island, there are of course attractive rates of personal taxation, including:

  • Higher Rate of Income Tax @ 20%
  • Income Tax Capped @ £200,000 of Contribution
  • 0% Capital Gains Tax
  • 0% Dividend Tax
  • 0% Inheritance Tax

Further, if you are coming from the UK, the NI records are maintained in both jurisdictions and there is a reciprocal agreement in place so that both records are taken into consideration for certain benefits. State pension is however separate i.e. contributions in the IOM/UK only relate to IOM/UK state pension.

Key employees can also gain further benefits; for the first 3 years of employment, eligible employees will only pay income tax, tax on rental income and tax on benefits in kind – all other sources of income are free of Isle of Man taxes during this period.

But there is so much more: the blend of country and town living, huge number of activities on your doorstep, warm and welcoming community, high rates of employment, low rates of crime, great schools and healthcare, an average commute of 20 minutes and much, much more – in many respects the island is very much what you make it.

Furthermore, unlike some crown dependencies, the Isle of Man has an open property market, which means that those seeking to live and work on the island are free to purchase property at the same rate as local buyers. Property is far more affordable than in other comparable jurisdictions, like Jersey or Guernsey. In addition, there is no Stamp Duty or Land Tax.

Whether starting your career or moving with your family to take that dream job, the Isle of Man is a very rewarding place to be. You can register on the Locate IM’s talent pool, which has been developed to help people looking to relocate to the Isle of Man find employment opportunities as easily as possible. This is a free Government service that can be found here.

How to Move to the Isle of Man – Immigration Routes

The Isle of Man Government offer various visa routes for individuals seeking to relocate, using a blend of UK and Isle of Man processes, which include:

  • Ancestral Visa – This route is dependent on the applicant having British ancestry no further back than grandparent. It is open to British Commonwealth, British Overseas and British Overseas Territories Citizens, along with British Nationals (Overseas) and Citizens of Zimbabwe. You can find out more here.
  • Isle of Man Worker Migrant Routes – there are four routes currently available:
  • Business Migrant Routes – There are two routes:

Locate IM have produced a series of case studies that give great insight into people’s experiences with relocating to the Isle of Man. Here are two very different but equally inspiring stories – Pippa’s Story and Michael’s Story and this great video made in conjunction with a couple who moved to the island to work in the accountancy sector (anon).

Happily Ever After – How Dixcart can help

In many ways, the island can still be advertised as a convenient, exciting, safe and rewarding destination for business, professionals and their families to relocate. Whether it is assistance with creating a start-up or redomiciling your existing company, Dixcart Management (IOM) Ltd are well placed to assist. Further, where you are seeking to immigrate to the Island on your own or with your family, with our extensive network of contacts, we will be able to make appropriate introductions.

Locate IM have produced the following video, which we hope peaks your interests:

Get in touch

If you require further information regarding moving to the Isle of Man and how we can assist, please feel free to get in touch with Team at Dixcart via advice.iom@dixcart.com

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

Why Everyone is Talking about the Portuguese D7 Visa or Digital Nomad Visa

Portugal, a country with the oldest borders in Europe, is easily accessible in terms of travel to and from the rest of the world, which makes it a very popular destination. The archipelagos of the Azores and Madeira are autonomous regions of Portugal and, like the mainland, offer amazing weather, a relaxed lifestyle, superb cuisine, excellent wines, and stunning scenery.

The Portugal D7 Visa, which is often called the Digital Nomad Visa or Passive Income Visa, is a good residence option for non-EU citizens who want to live in Portugal, such as digital nomads.

The D7 Visa is also an excellent option for pensioners who have sufficient passive foreign income to support themselves. This income can be, for example, from: property rentals, financial investments, profits and dividends from a company, salaries, pensions, etc.

What do you need to do to apply for the D7 Visa?

STEP 1

The first step is to obtain a Portuguese tax number and open a bank account at a Portuguese bank. Once the bank account has been opened, you need to deposit a minimum amount of funds, as set out below:

  • If you are applying on your own, you need to deposit EUR 8,460 per year, or more; OR
  • If you are applying as a couple, you need to deposit EUR 12,690 per year, or more.

This is a low minimum income requirement, and if you can prove that your income is above this amount, your D7 Visa application has a better chance of being successful.

STEP 2

The second step is to secure long-term accommodation in Portugal. This includes either buying a property (no minimum amount required on the price), or renting a property for at least 12 months.

STEP 3

The third step is to submit an online application for an interview with the Portuguese Consulate, in your country of residence. 

After the Portuguese Consulate has concluded the analysis of your application and the documents submitted, they will issue a Visa which is valid for 4 months, and will allow you to travel to Portugal (two entries into the country), to submit your residence permit application to the Portuguese Immigration authorities(SEF).

SEF will analyse the application and then issue the D7 Visa, which will be valid for 2 years. During those 2 years, you need to stay in Portugal for at least 6 consecutive months or 8 intermittent months, per year.

If you continue to meet all the requirements, your D7 Visa will be renewable for another 3 years.

Other advantages of a D7 Visa

  • Ability to obtain Non-Habitual Resident Status (NHR) for 10 years – this  includes exemption from tax on certain foreign income if specific requirements are met
  • Permanent Visa Free entry and circulation in the Schengen Area, for up to 90 days out of any 180 days
  • Family reunification
  • Access to Educational institutions (including those teaching in English, French and German)
  • Ability to work as an independent professional or as an employee
  • Access to the Portuguese Health care system (SNS)
  • After a period of 5 years, being able to apply for permanent residence or Portuguese citizenship.

What is the Difference between a Golden Visa and a D7 Visa?

There are two major differences between the Golden Visa and D7 Visa.

The first difference is that the Golden Visa requires a significant investment when compared to the D7 Visa.

In addition, the minimum stay requirements are very different: with a D7 Visa, the applicant cannot be outside of Portugal for more than 6 consecutive months or 8 intermittent months, in any one calendar year, whereas with a Golden Visa only 7 days a year, on average, is required to be spent in Portugal.

Why Should You Reach out To Dixcart?

There is extensive information available on the internet that may assist you in obtaining the D7 Visa program yourself, however, the truth is that this may come with many hurdles that our team are familiar with and that may be easily avoided with the help of a professional.

In addition, more than just a Visa is required when relocating to Portugal. Dixcart can provide tax planning, among other services, that can assist when relocating. Tax planning is considered necessary before your actual move to Portugal, as arriving unprepared may result in unfavourable tax consequences that could have easily been avoided.

Additional Information

Please contact Lionel de Freitas at the Dixcart office in Portugal at: advice.portugal@dixcart.com, for additional information. 

Non-UK Domiciled Individuals – the Importance of Pre-arrival UK Tax Planning

Introduction

Due to the impact it can have on an individual’s UK tax liability, it is vital that domicile is fully understood by those wishing to relocate to the UK permanently.

In general terms, if a non-domiciled individual wishes to move to the UK permanently and has no intention to return to their previous country, then there is a strong case they will be considered UK domiciled for tax purposes.

Effective tax planning, pre-UK arrival is therefore critical to avoid potential costly surprises in the future.

UK Domiciled vs Non-domiciled Impact

Firstly, let us briefly look at the UK tax implications for a person who is UK domiciled versus non-domiciled. Please note that both individuals are UK tax resident in the year for this illustration.

Mr UK Domiciled

  • Liable to tax on worldwide income and gains
  • Worldwide assets are subject to UK inheritance tax

Miss Non-domiciled

  • Worldwide income and gains are taxable on the arising basis
  • A claim for the remittance basis can be made which will mean Miss Non-domiciled will only be taxed on her foreign income and gains if she remits it to the UK. If it is kept offshore, she will not be subject to UK tax
  • Non-UK situs assets are excluded from UK inheritance tax

From this, we can see that Miss Non-domiciled position is usually more advantageous from a UK tax perspective. 

Determining your Domicile

In establishing whether a new domicile of choice has been created, careful consideration must be taken for the following points before making a decision to move to the UK:

  • the intentions of the individual;
  • their permanent residence;
  • their business interests;
  • their social and family interests;
  • ownership of property; and
  • the form of any Will that they have made.

This list is by no means exhaustive and there is no single criteria which determines whether an individual is or is not domiciled in the UK. Instead, a ‘balance of probabilities’ approach is taken.

Defend your Domicile

Taking into account the above, it is therefore essential to have provisions in place before arriving in the UK, to defend any potential challenge from HMRC.

Domicile enquires can be lengthy and intrusive should HMRC doubt an individual’s non-domicile claim. This can involve months or even years of correspondence involving various questions into; background, lifestyle and family and social connections, both from a historic perspective and to establish future intentions.   

Acquiring and maintaining evidence of strong, ongoing links to the country of domicile is crucial for those claiming non-domiciled status, and so is evidence of an intention to leave the UK at a future date. This can be particularly problematic on death, potentially bringing a foreign estate within the scope of UK inheritance tax.

To avoid any hiccups in the future, it may be worth considering having a domicile statement prepared, to provide contemporaneous evidence supporting the claim . 

Case Law

IRC v Bullock: Mr Bullock had a domicile of origin in Nova Scotia. He lived in England for 40 years. His wife did not want to live in Nova Scotia. Mr Bullock hoped to return there should he persuade his wife to change her mind or should he survive her. It was held by the Courts that he had a real determination to return rather than a vague aspiration. Accordingly he retained his Nova Scotian domicile of origin and had not acquired an English domicile of choice.

In contrast:

Furse v IRC: Mr Furse expressed a wish to live in England for the rest of his life save only for a contingency that he would return to the USA, should he cease to be physically able to take an active interest in his farm (situated in England). The Courts decided that this intention was so vague as to impose no limit on his intention to remain in England. Accordingly he had acquired an English domicile of choice.

Summary 

From the above we can see it is difficult to make a judgement without fully examining an individual’s position in detail.

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.

Due to HMRC’s increased number of investigations into the tax affairs of non-domiciled individuals, you should be prepared to present a robust defence in the event of any challenge from HMRC. A domicile statement can greatly assist, to provide evidence of an individual’s intentions, where it is supported by the facts, and can be particularly useful in situations where enquiries are opened by HMRC after death.

Additional Information

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

Malta Citizenship by Naturalisation for Exceptional Services by Direct Investment – helping Maltese Citizens

Background

In 2020 the Maltese government updated the citizenship legislation relating to citizenship by; birth, registration, naturalisation, dual and multiple citizenships, and exceptional services by direct investment.

A new residency route which can lead to Citizenship in Malta, was the outcome.

What are the Details of this New Residency Route?

  • ‘Maltese Citizenship by Naturalisation for Exceptional Services by Direct Investment,’ provides foreign individuals and their families, who contribute to the economic development of Malta, a route to become citizens of Malta.

Malta is a member of the European Union as well as a Schengen Member State, and its citizens can travel, live, work, study and set up business in any of the member countries, with visa-free travel rights to more than 180 countries.

Community Malta Agency (‘Agency’), is the authorised Maltese Government Agency responsible for administering the processing of all applications leading to Maltese Citizenship.

What are the Criteria?

To apply for Maltese Citizenship by Naturalisation for Exceptional Services by Direct Investment, an applicant needs; to invest in the Maltese economy directly, make a donation and hold residential property.

Direct Investment

Applicants, who can prove residency status in Malta for 36 months, prior to the naturalisation, are required to make a direct investment of €600,000. Whilst applicants who can prove residency status in Malta for at least 12 months, prior to naturalisation, are required to make a direct investment of €750,000.

If the applicant is accompanied by qualifying dependants, a further investment of €50,000 per dependant needs to be made. 

An applicant cannot apply for a certificate of citizenship by naturalisation for exceptional services, before he/she has proved that he/she has become a resident of Malta for the minimum period required.

Philanthropic Nature of Direct Investment

Prior to the issue of a certificate of Maltese citizenship, the applicant must donate a minimum €10,000 to a registered philanthropic, cultural, sport, scientific, animal welfare or artistic non-governmental organisation or society, or as otherwise approved by the Agency.

In addition, the main direct investment made by each applicant will be used by the Government to finance projects coordinated by The National Development and Social Fund, across Malta.

Projects that Benefit from The National Development and Social Fund

The National Development and Social Fund agency (‘Fund’) was established to manage and administer 70% of the contributions received from the Individual Investor Programme of the Republic of Malta, set up under the Malta Citizenship Act Cap.188.

The Fund’s mission is to; contribute towards, promote and support significant projects and initiatives of national importance and of public interest, which are intended to develop and improve the economy, public services, and the general well-being of present and future generations.

Between July 2018 and June 2019, the total contributions, including property purchases, rents, and investments, collected through the Programme amounted to more than €271 million. This equates to approximately 2.11% of Malta’s GDP in the same period. The total amount collected, since the changes implemented in the 2020 citizenship legislation, exceed €930 million. Of these funds, approximately €515 million have been allocated to the National Development and Social Fund.

More Details about the Projects

The fund has invested in the following projects:

  • €10 million to upgrade eight health centres and 54 clinics. Previously, the Fund awarded a grant of €950,000 to Mater Dei Hospital’s Cardiology Department to upgrade its two catheterisation suites, and €5 million to Puttinu Cares to purchase apartments for cancer patients and their families in London.
  • In Feb 2019, a memorandum was signed to commit €50 million towards a social housing project. Five hundred new social housing units to be built, across 22 different sites. These sites are spread over 12 localities; Paola, Kirkop, Rabat, Żabbar, Mellieħa, Luqa, Żurrieq, Żebbuġ, Qormi, Siġġiewi, Qrendi and Marsascala.
  • In Ħamrun, a planned roof garden of around 500m2, with more than 2,500 trees, shrubs and plants including mature carob, olive and oak trees, will be featured in the square. This garden will absorb around 900 kilograms of carbon dioxide from the atmosphere, whilst producing 660 kilograms of oxygen.
  • Other investments allocated by the Fund include;  €1.5 million for Caritas, a €1.5 million investment in artistic heritage, and €3.5 million in Urban Green projects.

In 2020, the Fund received €27.8 million from Community Malta Agency, with the total proceeds received from inception being €599.8 million.

Investment in Education

An agreement was signed at the Wardija Resource Centre, part of the Maria Regina College, offering special education beyond the compulsory school age. With an investment of around €40,000, teaching will take place in a multisensory room, where skills related to students’ senses will be developed.

In addition, in collaboration with the University of Malta, a new garden will be planted to create a habitat for endemic butterflies and to enhance their reproduction chances. Another section is to have an apiary where students can learn and enjoy their free time.

At St Paul’s Bay’s Primary School, a room dedicated to creativity and innovation will be launched with an investment of €35,000. Teaching will be undertaken in interdisciplinary ways, mixing; science, technology, engineering, and the arts to increase students’ scientific, literacy and critical thinking.

Finally, at Naxxar’s Senior School, an investment of around €30,000 will be used for new curtains and a mechanised projector for the school’s stage. This is to encourage students to participate in visual and artistic activities, as this will help them learn to think creatively and develop critical thinking, which can be applied in all areas of learning.

Quota for the New Residency Route

It is important to be aware that a maximum quota of 400 applicants per year has been set, with a total maximum number of applicants set at 1,500, for the entire scheme.

Additional Information

If you would like further information regarding Maltese Citizenship by Naturalisation for Exceptional Services by Direct Investment, please contact the Dixcart office in Malta: advice.malta@dixcart.com or your usual Dixcart contact.

Dixcart Management Malta Limited Licence Number: AKM-DIXC-22

Property Taxes in Portugal – The Importance of Getting it Right

Popularity of Portuguese Property

Portugal features as an all-time favourite with picturesque views of ancient and new buildings on the sunny hills of this new favourite European gem. A zoomed in view of these include glazed blue ceramic tiles, or azulejos, covering the exterior walls of buildings.

Property has recorded double digit percentage growth in various sectors listed by numerous real estate service companies in recent years and the expectation is that this will continue – with an increased demand and reduced supply than previously seen.

What is an interesting misconception is that property prices are driven predominantly by the Golden Visa program – in actual fact, the Portuguese Golden Visa accounts for an insignificant portion of property purchases, when considered in comparison to total property purchases in Portugal.

This reflects that there are various factors in Portugal influencing properties prices, including: the fact that Portugal is the new acclaimed California, the new European Silicon Valley, it is ranked one of the best places to live and work in the world, it is an attraction magnet for digital nomads, as well as offering a 10-year tax holiday for the affluent, and there is more.

Property has always been a favourable investment class for many – and that is no different now. This raises the importance of understanding the related tax consequences for holding property in Portugal.

Below Dixcart have summarised some of the tax implications applicable in Portugal.

What are the Tax Consequences for My Rental Income?

Rental income, for individuals is taxed at a flat rate of 28% – for both resident and non-resident Portuguese holders of property. It is worth noting that residents may use the marginal scale rates if lower – although it is unlikely they will be able to do so.

Qualifying expenses may be used to reduce the taxable income due – provided it forms part of the income producing activity.

Corporate tax rates for rental income depend on residency status: non-resident entities may be subject to 25% tax, whereas local Portuguese companies will be subject to tax at rates between 19% to 21% in mainland Portugal and 11.9% to 14.7% for properties located in the autonomous region of Madeira.

When is Stamp Duty Applicable?

Stamp duty is applicable on a variety of transactions in Portugal – this may occur when a property is inherited or when a property is purchased. Please refer below for more details.

What Inheritance Tax Implications Exist for Property (or is it Stamp Duty that Applies)?

Although inheritance tax is not applicable in Portugal, stamp duty does apply.

For the purposes of stamp duty, inheritance or gifts may fall into one of two categories – those which are exempt, and those taxed at a flat rate of 10%. Inheritances by close relatives, such as parents, children and spouses, are exempt from stamp duty. All other inheritances and gifts are taxed at a flat stamp duty rate of 10%.

Stamp duty is payable for the respective property, even if the recipient does not live in Portugal.

If you are a UK domicile, your Portugal property will form part of your UK estate for UK inheritance tax purposes.

Stamp Duty on the Purchase of a Property

Stamp duty on the purchase of a property is charged at a rate of 0.8% at the higher of the purchase price or VPT (the rateable value, attributed by the tax authorities). The VPT in most cases is much lower than the actual purchase price of the property.

The purchaser must pay this duty, prior to signing the final deed, and proof of payment will need to be provided to the notary.

VAT may be applicable on the purchase of new builds in particular situations.

Property Transfer Tax

Property transfer tax, namely IMT (Imposto Municipal sobre Transmissões Onerosas de Imóveis), is applicable each time ownership is transferred. The tax is required to be paid by the purchaser prior to the final deed of sale being signed (as the original copy of proof of payment needs to be shown to the notary at the time of the property exchange).

The tax paid, is calculated on the higher of the purchase price or the VPT.

The property transfer tax rate is largely dependent on the ultimate use of the property and whether it is your first or second home, with the rates varying between 0% and 6%.

Annual Municipal Property Tax (IMI)

Annual municipal property tax, or IMI (Imposto Municipal sobre Imóveis), is payable by the person who is the property owner as at 31 December of the previous year, and is based on the VPT. The rate applied ranges from 0.3% to 0.8%, and is dependent on whether the property type is classified as urban or rural (classified by the Portuguese tax authorities based on the location of the property). Note that any investor or company located in a blacklisted tax jurisdiction, in accordance with the Portuguese tax authority, will be subject to a flat rate of 7.5% IMI.

An additional annual municipal property tax, namely AIMI (Adicional ao IMI), is chargeable for any VPT value exceeding €600,000, for all residential properties and construction plots, at a rate of 1%. Thus, the first €600,000 will be subject to the IMI at the respective IMI rate, and the excess value above €600,000 will be subject to AIMI at rates that vary between 0.4% and 1.5%.

Please note that AIMI is not only considered for a single property but considered per owner and therefore, if more than one property is held, the cumulative VPT needs to be considered. If the cumulative VPT value of all properties held by a single owner exceed €600,000, AIMI will be applicable on the value of the properties held, exceeding this threshold.

What Tax Consequences are Applicable Upon the Sale of a Property?

Capital gains tax is applicable on the sale of a property, unless purchased before 1989.

The tax consequences vary dependent on whether you are resident or non-resident. In addition, the use of the property and the way that the proceeds from the sale are utilised are paramount, as this may have a significant impact on the related tax consequences applicable.

The tax is calculated on the difference between the selling price and the acquisition value (adjusted for inflation rates, net of documented costs incurred when the property was acquired, coupled with any capital improvements within the last 12 preceding years of the sale).

As a Portuguese tax resident, 50% of the gain is required to be paid. If the property was held for a period of two years or more, inflation relief may also be applicable. Capital gains, on your property, are added to your other annual income and are taxed at marginal tax rates of up to 48%.

It is worth noting that gains resulting from the sale of a primary residence are exempt for residents, if you reinvest all of the proceeds (net of any mortgage on the property), in another main home in Portugal or the EU/EEA, before the property is sold (a window of up to 24 months), or within 36 months of the disposal of the property, provided you live in the new property, within 6 months of the purchase.

Capital gains are taxed at 28% for non-residents individuals and 25% for non-resident companies.

However, the tax consequences in Portugal are not the only consideration to bear in mind. One also needs to consider the double taxation treaty and local laws and regulations applicable in the country of tax residency.

A typical example of this for a UK resident, is the fact that UK tax residents also pay tax on the gain from the Portuguese property in the UK, however, under the double taxation treaty, any tax paid in Portugal may be credited against the tax due in the UK.

Is there a Preferred Structure to Hold Property in Portugal?

A topical query – what is the most preferred and tax efficient structure to hold property in Portugal?

Although the answer may vary dependent on objectives and circumstances from one investor to the next, as well as the purpose for such properties, it is worth noting that as a non-tax resident investor wishing to invest in property to earn rental income, holding such a structure through a Portuguese company may be more beneficial with tax rates varying between 19% to 21% and 11.9% to 14.7%, for properties located in Portugal mainland and the autonomous region of Madeira respectively, in comparison to the flat rate of 25% for non-resident entities.

For residents, holding a primary residence in their personal capacity, may be more beneficial from a capital gain point of view. Thus, each situation needs to be considered on a case-by-case basis.

Other considerations, however, need to be taken into account, such as the operational costs for running a company and ensuring appropriate substance exists. The cost of holding a property through a corporate structure may thus not exceed the benefit in all circumstances.

Alternative qualitative benefits may include the fact that corporate structures provide an extra layer of asset protection, which may be considered invaluable for many individuals located in jurisdictions exposed to considerable financial and other types of risk.

Summary of Property Tax Consequences

To summarise the tax and costs applicable for purchasers, owners, sellers and others, as discussed above, please refer below:

Purchaser:Owner:
IMT (Property Transfer Tax)Stamp DutyNotary/Registration CostsLegal expensesIMI (Annual Municipal Tax)AIMI (in addition to IMI)Running costs (such as water and electricity)
Seller:Others:
Capital gainsCommission to real estate agencyInheritance tax

The related tax rates may be summarised as follows:

Individuals
 ResidentsNon-Residents
Capital Gains TaxPrimary residence may be subject to exemptionSecond property will be taxed at 28%28%
Rental IncomeLower of 28%; orMarginal tax rate.28%
Companies
 ResidentNon-Resident
Capital Gains Tax28%25%
Rental IncomeRespective company tax rate, namely: Madeira: 11.9% to 14.7%Portugal: 19% to 21%25%

Why is it Important to Engage with Dixcart?

It is not just the Portuguese tax considerations on properties, largely outlined above, but also the impact from where you may be tax resident and/or domiciled, that need to be considered. Although property is typically taxed at source, double taxation treaties and double tax relief need to be considered.

A typical example is the fact that UK residents will also pay tax in the UK and this will be calculated based on UK property tax rules, which may be different to those in Portugal.  They are likely to be able to offset the Portuguese tax actually paid against the UK liability to avoid double taxation, but if the UK tax is higher, further tax will be due in the UK. Dixcart will be able to assist in this regard and to help make you aware of your obligations and filing requirements.

How else may Dixcart Assist?

Dixcart Portugal have a team of experienced professionals who may assist with various aspects regarding your property; efficient tax planning, legal support (for the sale or purchase of a property), accounting and tax support and the incorporation and maintenance of companies.

Further to this, if you would like a deemed tax calculation to be performed, you may reach out to our offices in Portugal and/or Madeira for this information: advice.portugal@dixcart.com

Dixcart have helped many with this service and look forward to assisting you with your next property advice and/or transaction.

UK High Potential Individual (HPI) Visa – What You Need to Know

The High Potential Individual (HPI) visa is designed to attract top global graduates from prestigious universities around the work, who want to work, or look for work in the UK, following the successful completion of an eligible course of study equivalent to a UK bachelor’s degree level or above. The study must have been with an institution listed on the Global Universities List, the table of global universities that will be accepted for this visa route as awarding institutions, which is updated regularly.

The new High Potential Individual route, launched on 30 May 2022, is an unsponsored route, granted for 2 years (Bachelors and Masters holders), or 3 years (holders of a PhD).

Eligibility Requirements

  • The HPI is based on a points-based system. The applicant needs to obtain 70 points:
    • 50 points: The applicant must, in the 5 years immediately before the date of the application, have been awarded an overseas degree level academic qualification which ECCTIS confirms meets, or exceeds, the recognised standard of a UK bachelor’s or UK postgraduate degree. From an institution listed on the Global Universities List.
    • 10 points: English Language requirement, in all 4 components (reading, writing, speaking and listening), of at least level B1.
    • 10 points: Financial requirement, applicants must be able to demonstrate that they can support themselves within the UK, with a minimum cash fund of £1,270. Applicants who have lived in the UK for at least 12 months under another immigration category, do not have to meet the financial requirement.
  • If the applicant has, in the last 12 months before the date of application, received an award from a Government or international scholarship agency covering both fees and living costs for study in the UK, they must provide written consent to the application from that Government or agency.
  • The applicant must not have been previously granted permission under the Student Doctorate Extension Scheme, as a Graduate or as a High Potential Individual.

Dependants

A High Potential Individual can bring their dependant partner and children (under the age of 18) to the UK.

Staying Longer in the UK

The High Potential Individual route is not a route to settlement. A High Potential Individual is not able to extend their visa. However, they may be able to switch to a different visa instead, for example a Skilled Worker visa, Start-up visa, Innovator visa, or Exceptional Talent visa.

Additional Information

If you have any questions and/or would like tailored advice on any UK immigration matter, please speak to us at: advice.uk@dixcart.com, or to your usual Dixcart contact.

Switzerland – Could this be your Next Move?

Switzerland is an enchanting country, blessed with spectacular hiking and skiing trails, beautiful rivers and lakes, picturesque villages, Swiss festivals throughout the year, and, of course, the spectacular Swiss Alps. It appears on almost every bucket list of places to visit but has succeeded in not feeling over-commercialised – even with the tourists flocking to the country to try the world-famous Swiss chocolates.

Switzerland features almost at the top of the list of most attractive countries for high-net-worth individuals to live. It is one of the world’s wealthiest countries and is also known for its impartiality and neutrality.

Switzerland offers an exceptionally high standard of living, first-rate health service, outstanding education system, and boasts a plethora of employment opportunities.

Switzerland is also ideally situated for ease of travel; one of the many reasons high-net-worth individuals choose to relocate here. Perfectly situated in the middle of Europe means moving around could not be easier, especially for individuals who regularly travel, internationally.

Swiss Residence

There are no restrictions imposed on permanent residence for EU/EFTA nationals and these individuals enjoy priority access to the labour market. Should an EU/EFTA citizen wish to live and work in Switzerland, they can freely enter the country but will need a work permit to stay more than 3 months.

Regarding EU/EFTA nationals who do not want to work in Switzerland, the process is even more straightforward. Individuals must show they have sufficient funds to live in Switzerland and take out Swiss health and accident insurance.

The process is a bit longer for non-EU and non-EFTA (European Union Free Trade Association) nationals. Those who wish to live and work in Switzerland are allowed to enter the Swiss labour market, but must be appropriately qualified (such as managers, specialists, and those with higher education qualifications). They will also need to be registered with the Swiss authorities in order to obtain a work visa, and they will need to apply for an entry visa from their home country.

Non-EU/EFTA nationals who want to move to Switzerland, but not to work, are divided into two age categories. Depending on which category the individual falls into (over 55 or under 55), certain criteria must be met (more information can be provided on request: advice.switzerland@dixcart.com).

Taxation in Switzerland

One of the greatest motivations for moving to Switzerland is the attractive tax regime available to individuals who choose to live there. Switzerland is divided into 26 cantons and each canton has its own cantonal and federal taxes that generally impose the following taxes: income, net wealth, and real estate.

A significant advantage of the Swiss tax regime is that the transfer of assets in Switzerland, before death (as a gift), or on death, to a spouse, or to children and/or grandchildren is exempt from gift and inheritance tax, in most cantons. In addition, capital gains are generally also tax free, except in the case of real estate.

The federal and cantonal tax laws of most cantons provide for a special Lump Sum Tax Regime for foreigners who move to Switzerland for the first time, or after an absence of ten years, and who will not be employed or commercially active in Switzerland. It is an extremely attractive tax regime as it enables individuals to manage their worldwide investments from Switzerland.

Individuals benefiting from the Lump Sum System of Taxation are not subject to Swiss taxation on their worldwide income and net wealth, but on their worldwide expenditure (living expenses). The minimum requirement for calculating income tax based on expenses for individuals with their own household, is the equivalent of seven times the annual rental value of their principle residence in Switzerland. In addition, a minimum taxable income of CHF 400,000 is assumed for direct federal taxation. Cantons may also define minimum expense thresholds, but the amount is at their own discretion. Some cantons have already stated their minimum threshold amounts and these will vary from canton to canton.

Living in Switzerland

Although Switzerland has a variety of beautiful towns and alpine villages to live in, expats and high-net-worth individuals are mainly drawn to a few specific cities. At a glance, these are Zürich, Geneva, Bern and Lugano.

Geneva and Zürich are the biggest cities due to their popularity as centres for international business and finance. Lugano is located in Ticino, the third most popular canton, as it is close to Italy and has a Mediterranean culture many expats enjoy.

Geneva

Geneva is known as the ‘international city’ in Switzerland. This is due to the high number of expats, the UN, banks, commodity companies, private wealth companies, as well as other international companies. Many businesses have set up head offices in Geneva. However, the main attraction for individuals, continues to be the fact that it is in the French part of the country, has a well-looked-after old town full of history and culture and boasts Lake Geneva, with a magnificent water fountain which reaches 140 meters into the air.

Geneva also has fantastic connections to the rest of the world, with a large international airport and connections to the Swiss and French rail and motorway systems.

In the winter months, residents in Geneva also have very easy access to the Alp’s best ski resorts.

Zürich

Zürich is not the capital of Switzerland, but it is the largest city, with 1.3 million people within the canton; an estimated 30% of the residents in Zürich are foreign nationals. Zürich is known as the Swiss financial capital and is home to many international businesses, especially banks. Even though it gives the image of high-rise buildings and a city lifestyle, Zürich has a beautiful and historical old town, and an abundance of museums, art galleries and restaurants.  Of course, you are also never too far from the lakes, hiking trails and ski slopes if you love being outdoors.

Lugano and the Canton of Ticino

The canton of Ticino is the southernmost canton of Switzerland and borders the canton of Uri to the north. The Italian-speaking region of Ticino is popular for its flair (due to its proximity to Italy) and fantastic weather.

Residents enjoy a snowy winter but in the summer months, Ticino opens its doors to tourists who flood to its sunny coastal resorts, rivers and lakes, or sun themselves in the town squares and piazzas.

In Switzerland, four different languages are spoken, and English is well spoken everywhere.

Additional Information

I hope this article has inspired you to visit Switzerland and to consider this incredible country as a place of residence. No matter which canton draws your attention, or which city you decide to settle in, the rest of the country, and Europe, is easily accessible. It may be a small country, but it offers; a diverse range of places to live, a dynamic mix of nationalities, is headquarters to many international businesses, and caters to a large range of sports and leisure interests.

The Dixcart office in Switzerland can provide a detailed understanding of the Swiss Lump Sum System of Taxation, the obligations that need to be met by applicants and the fees involved. We can also give a local perspective on the country, its people, the lifestyle, and any tax issues. If you would like to visit Switzerland, or wish to discuss moving to Switzerland, please do get in touch: advice.switzerland@dixcart.com.

Moving to Switzerland and Want to Work? The Benefits of Forming a Swiss Company

The procedure for relocating to Switzerland is made easier for both EU/EFTA nationals and non-EU/EFTA nationals, if the new resident forms a Swiss company and is employed by it.

If you are looking for a high quality of life in one of the world’s most economically and politically stable countries, living in Switzerland could provide you with the ideal answer. Not only will you find yourself at a central hub for travel to over 200 international locations, but you will also have access to the beautiful scenery of the Alps and picturesque lakes.

There are two options for moving to Switzerland – but the main question is do you wish to work once you have moved?

This article explores the following:

  1. Why Switzerland?
  2. Who Can Move to Switzerland?
  3. Forming or Investing in a Swiss Company
  4. Criteria for Forming a Swiss Company
  5. How to Invest in a Swiss Company?
  6. Benefits – Tax and Residence
  7. Living in Switzerland

1. Why Switzerland?

Switzerland is an attractive jurisdiction to start and operate a business, as a location for individuals and for family protection and safety. 

Advantages include:

  • Located in the centre of Europe.
  • Economic and political stability.
  • High regard for personal privacy and confidentiality.
  • Most ‘innovative’ and “competitive” country in the world with various strong industries.
  • A well-respected jurisdiction with an excellent reputation.
  • A high quality and multilingual local workforce.
  • Low rates of corporate tax for Swiss companies.
  • Premier destination for international investment and asset protection.
  • Major commodity trading centre in the world.
  • Hub for HNWIs, international families and a wide variety of professionals including lawyers, family offices, bankers, accountants, insurance companies.

2. Who can Move to Switzerland?

  • EU/EFTA nationals: enjoy priority access to the labour market. They can freely enter the country but will require a work permit. The individual will need to find a job and the employer must register the employment before the individual can actually start to work.
  • Non-EU/EFTA nationals: are allowed to enter the Swiss labour market if they are appropriately qualified, for example managers, specialists, and those with higher educational qualifications. The employer needs to apply to the Swiss authorities for a work visa, while the employee applies for an entry visa from their home country. The work visa will allow the individual to live and work in Switzerland.

3. Forming or Investing in a Swiss Company and Becoming a Director or an Employee of the Company

The establishment of a Swiss company is one of the most popular routes for individuals relocating to Switzerland. This is because EU/EFTA and non-EU/EFTA nationals can form a Swiss company, be employed by it, reside in Switzerland, and benefit from the attractive tax regime.

Any foreign national can form a company and therefore potentially create jobs for Swiss nationals. The owner of the company is eligible for a residence permit in Switzerland, as long as he/she is employed by the company in a senior capacity.

4. What are the Criteria?

In principle, non-EU/EFTA nationals need to form a company which must:

  • generate an annual minimum turnover of CHF 1 million, and
  • create new jobs exploiting new technologies and/or the development of the region and contribute to the economic development of the country.

The company must produce a business plan detailing how the amount to be invested will generate a turnover of CHF 1million or more per annum, in the ‘near’ future. The business plan also needs to show that the company will achieve this turnover in a specified number of months, not necessarily in the first year, particularly if the company is a start-up.

The types of economic development objectives for the company, which are regarded positively in Switzerland, include: opening up new markets, securing export sales, establishing economically significant links abroad, and the creation of new tax revenue. Precise requirements vary by canton and more information can be provided on request.

Alternatively…

5. Investment in a Swiss Company

Alternatively, EU and non-EU/EFTA applicants can choose to invest in a company which is struggling to expand, as it lacks the necessary funding.

For non-EU/EFTA applicants this new funding should then enable the company to create jobs and assist the Swiss economy to expand. The investment must add economic value to a particular Swiss region.

6. Benefits of a Swiss Company – Tax and Residence

  • Taxation of Swiss Companies

Swiss companies can enjoy a zero-tax rate for capital gains and dividend income, depending on the circumstances, and Trading companies are taxed as follows:

  • The effective cantonal and federal corporate income tax rate (CIT) is between 12% and 14% in most cantons. The Geneva corporate tax rate is 13.99%.

Swiss Holding Companies benefit from a participation exemption and do not pay tax on profits or capital gains arising from qualifying participations. This means that a pure Holding Company is exempt from Swiss tax.

Withholding Tax (WHT)

  • There is no WHT on dividend distributions to shareholders based in Switzerland and/or in the EU (due to the EU Parent/Subsidiary Directive).
  • If shareholders are domiciled outside Switzerland and outside of the EU, and a double tax treaty applies, the final taxation on distributions is generally between 5% and 15%.

Double Tax Treaties

Switzerland has an extensive double tax treaty network, with access to tax treaties with over 100 countries.

For more information about Swiss Companies, please read our article: Formation of a Swiss Company.

  • Taxation of Individuals

Each canton sets its own tax rates and generally imposes the following taxes: income, net wealth, real estate, inheritance, and gift tax. The specific tax rate varies by canton and is between 21% and 46%.

In Switzerland, the transfer of assets, on death, to a spouse, children and/or grandchildren is exempt from gift and inheritance tax, in most cantons.

Capital gains are generally tax free, except in the case of real estate. The sale of company shares is one of the assets, that is exempt from capital gains tax.

7. Living in Switzerland

Switzerland ranks among the top countries in the world in which to live due to its high quality of living and reputation as a centre of international trade and finance. It is one of the world’s wealthiest countries and is also known for its impartiality and neutrality.

Switzerland is blessed with spectacular hiking and skiing trails, exclusive swimming spots in the many rivers and lakes, picturesque villages, Swiss festivals throughout the year, and, of course, the Swiss Alps which look spectacular during any season.

Switzerland offers an exceptionally high standard of living, first-rate health service, outstanding education system, and boasts a plethora of employment opportunities.

Switzerland is one of 26 countries in the ‘Schengen’ area and a Swiss residence permit will enable you to enjoy full Schengen travel rights. It is therefore ideally situated for ease of travel; one of the many reasons high-net-worth individuals choose to relocate here. Perfectly situated in the middle of Europe means moving around could not be easier, especially for individuals who regularly travel, internationally.

Although Switzerland has a variety of beautiful towns and alpine villages to live in, high-net-worth individuals are mainly drawn to a few specific cities. At a glance, these are Zürich, Geneva, Bern, and Lugano. Geneva and Zürich are the biggest cities due to their popularity as centres for international business and finance. Ticino is the third most popular canton, as it is located close to Italy and has a Mediterranean culture.

Additional Information

If you would like additional information regarding moving to Switzerland and forming a Swiss Company, please contact Christine Breitler at the Dixcart office in Switzerlandadvice.switzerland@dixcart.com.