Financial Information
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Italian fixed tax regime or “res-non-dom” scheme
Following on from the UK’s assault on the resident non-domiciled rules, Italy has introduced a very attractive alternative for those seeking certainty at a reasonable cost right in the heart of Europe. From 1st January 2017 individuals can transfer tax residence to Italy and gain benefit from a fixed flat…
Re-engineering of the Mauritius Financial Services Sector
The Honourable Prime Minister, Pravind Kumar Jugnauth, in its recent declaration, affirms all stakeholders that Mauritius International Financial Centre (‘IFC’) is substance driven and fully supports the application of best practices recommended by globally recognized institutions. He stated that Mauritius is being transformed from a treaty centric to a substance…
South African Yachting Crew. How to plan your affairs
The world’s yachting management business is large and attracts staff from around the world. The South African contingent has been growing considerably of late, not least because it offers an opportunity to work with limited passport and visa issues. The question arises though, as to how to optimize that opportunity…
BVI Limited Partnership Act, 2017 improves partnership offering.
In early 2018 the new BVI Limited Partnership Act, 2017 (the “LPA”) was brought in to force with the Registry of Corporate Affairs in the British Virgin Islands accepting the registration of limited partnerships under the LPA. The LPA was intended to provide a platform for subscription finance transactions and…
BVI modernises AML requirements to recognise new technologies
Following consultation with the Joint Anti-Money Laundering and Terrorist Financing Advisory Committee (JALTFAC), the Anti-Money Laundering Code was amended on 19 July 2018 by means the Anti-Money Laundering and Terrorist Financing (Amendment) (No. 2) Code of Practice, 2018. The amendments came into force as of 1 August 2018. The major…
Ireland Ghana Tax Treaty Negotiations Concluded.
In an announcement on the 18th August 2016 the Ireland announced that it had concluded negotiations on a new DTT with Ghana. No details of the treaty itself are yet available. This adds to the 9 existing treaties that Ghana has concluded most of which are with European countries. It…
New Cayman LLC Company Law Comes Into Effect
Within the investment industry, the good news announced recently has been the eagerly awaited introduction of a new type of vehicle in the Cayman Islands, namely the Limited Liability Company. The Cayman Islands Government has announced that the anticipated Limited Liability Companies Law, 2016 (“LLC Law”) will come into force…
Cyprus: Citizenship By Investment Programme
For many wealthy people stuck with a passport that makes travel and the right to live elsewhere difficult, the search for an acceptable jurisdiction to base yourself has been a worthwhile pursuit. With the advent of Brexit this might well now include UK citizens who are keen to have a…
Brexit: EU Parent Subsidiary Directive Implications
The implications of Brexit are continually coming to the fore and we will examine them as they surface. One of the benefits for a company of being incorporated in the EU is that any number of provisions have been implemented in order to avoid tax obstacles for companies operating across…
Mauritius Private Pension Scheme from Osiris Corporate Solutions
New legislation enacted in Mauritius brings opportunity to create international pension scheme for non-residents. On the 1st of November 2012, the Private Pension Scheme Act (PPSA) came into effect in Mauritius and with it the exciting prospect of providing a framework for establishing financial vehicles that satisfy the need for…
Brexit: Right to Live and Work in Europe and the UK
Well Brexit is upon us. What has been posed as a possibility is now a reality, and the implications are only just beginning to be absorbed. David Cameron has resigned and indicated that he will leave it up to his successor to invoke Article 50 of the Treaty to start…
IPPA And GECA Between Mauritius And Côte D’Ivoire
The 5th Edition of the Economic Forum, organized by the General Confederation of Enterprises of Côte d’Ivoire (CGECI – Ivorian National Council of Employers), known as the CGECI Academy was held on 21 and 22 April 2016 in Abidjan, Côte d’Ivoire. Mauritius was invited to this event as Guest of…
Investment Promotion and Protection Agreement – Mauritius and Sao Tomé Principe
Sao Tomé & Principe located in the Golf of Guinea is a former Portuguese colony, well known for its petroleum exploration which started during the late 1980s and which has since developed and where the potential exists, for further development of the country’s petroleum industry. On 6 May 2016, Mauritius…
Mara Delta Property Holdings Open New Offices in Mauritius
Following on from the relocation of several senior executives into Mauritius, Mara Delta have now moved into new offices of their own in Grand Bay. Mauritius has proved to be a superb location for Mara Delta including a successful listing on the Stock Exchange of Mauritius but also from an…
Mauritius India Protocol to Double Tax Treaty Signed
The Mauritius-India DTT was entered into in 1983. The 1990’s brought about the Mauritian Global Business Services by encouraging foreign investors to channel their investments in India through companies set up in Mauritius. For the past few years it has been argued by Indian authorities that a large number of…
Mauritius Signs IPA with Ivory Coast
It has been announced on April 26th that Mauritius and Ivory Coast have signed an Investor Protection Agreement in Abidjan. It was also announced that Mauritius and Ivory Coast are in negotiations for the conclusion of a double tax treaty between them. The treaty is expected to be signed shortly…
UK Spring Budget 2016: Update for Res Non Doms
George Osborne’s eighth Budget has reiterated the announcement made in the Summer Budget 2015 that UK Res Non Doms who have been resident in the UK for 15 out of the past 20 years will become deemed UK domiciled, for all taxes, after 5th April 2017, thus bringing to an…
Code For Corporate Governance In Mauritius: Revised
The National Committee for Corporate Governance (NCCG), which was established in September 2001 has been mandated to promote principles of good corporate governance (accountability, transparency, responsibility, fair treatment, meritocracy, management disciplines, and fight against corruption) amongst public and private sector organisations. It is in 2004 that the NCCG published the first…
Mauritius Population Is Richest In Africa
MAURITIUS’ population is the richest in Africa with an average wealth of US$21,700 per person, while Zimbabwe’s is the poorest with a per capita wealth of just 200 dollars, a new Research and Markets report titled “The Africa 2016 Wealth Report” showed. Mauritius was ranked ahead of South Africa with a…
Malta: Citizenship By Investment
Osiris has for many years assisted clients who require to move their home to a new location. It is always a difficult choice but one located, like Malta, in the center of the EU will always be of interest, particularly as this program, like the Portuguese one, offers full citizenship…
South Africa and United Arab Emirates sign new Income Tax Treaty
On the 23rd November 2015, a new Income Tax Treaty was signed between South Africa and the United Arab Emirates (UAE). The treaty generally follows the OECD Model (2008). The maximum rates of withholding tax are: 10% on dividends and 5% if the beneficial owner is a company the capital…
Ireland Signs Three Key Double Tax Treaties in Africa: Zambia, Morocco and Botswana.
Ireland has for a long time positioned itself as a key entry point into Europe and has had virtually no treaties into Africa. Given that one of its key industries is the aircraft leasing business, with virtually every major aircraft and helicopter leasing company being based in Ireland, it was…
The New EU Succession Regulation
With the spirit of bringing about ‘measures aimed at ensuring the compatibility of rules applicable in Member States concerning conflict of laws and of jurisdiction’ the newly EU enacted “EU Succession Regulation” (“the Regulation”) 2012 has brought about much needed legal certainty around succession law in the EU. The new…
Register of People with Significant Control of UK Companies
In an effort to increase transparency over who owns and controls UK companies and assist with anti-money laundering initiatives, from 6 April 2016, UK companies and limited liability partnerships will be required to identify and keep a register of Persons with Significant Control (PSC) of that entity. This register will…
BVI Register of Directors: An Update
In December 2015 we noted that the BVI had introduced a requirement to file a Register of Directors. There has now been a further update to the requirement to file a Register of Directors. This is now a mandatory requirement with effect from 1 April 2016. The filing dates and…
South Africa: Special Voluntary Disclosure Programme In Respect Of Offshore Assets And Income
In his Budget Speech on Feb 24 2016, the South African Minister of Finance announced what has been called a “Special Voluntary Disclosure Programme”. The program looks very similar to previous amnesties offered in respect of offshore assets and applies in respect of both Income Tax and Exchange Control, although…
Delta Africa Property Holdings Ltd Releases Mid-Year Results
Delta Africa Property Holdings Ltd (Delta) has just released its mid-year results, see below. Delta is a Mauritius GBC1 which is listed on the stock exchange of Mauritius and the main board of the Johannesburg Stock Exchange. Osiris is pleased to see this superb set of results being announced as…
South African Exchange Controls: A Planning Perspective
South African exchange controls were introduced into South Africa in 1978, and despite having been relaxed over the years, remain as firmly entrenched as ever. Certainly when I started work as an articled clerk in 1986, my principal at the time informed me that they would be abolished shortly. 30…
Astoria Investments Ltd: A Mauritius GBC1 With A Secondary Listing On Namibian Exchange
Astoria Investments Ltd is a Mauritius GBC1 with a primary listing on the Stock Exchange of Mauritius and a secondary listing on the Alt x of the Johannesburg Stock Exchange. These listings took place in November 2015. Astoria has now successfully concluded a further secondary listing on the Namibian Stock…
BVI FSC Confirm Delay of the Implementation of Common Reporting System (CRS)
On the 1st of January 2016 legislation to implement the CRS rules came into effect. Premier and Minister of Finance, Dr. the Honourable D. Orlando Smith, OBE, said last year that the Common Reporting Standard (CRS) has become the standard for automatic exchange of financial account information in tax matters and…
Mauritius Revenue Authority Confirm Delay of the Implementation of CRS
On the 22nd December the MRA announced that the 1 January 2016 implementation of CRS has been deferred. On 15 January 2016 they released a new communique announcing the following: “Further to our communiqué dated 22nd December 2015, this is to inform all stakeholders that the first exchange of information…
Hong Kong And China Sign The 4th Protocol To The Double Tax Treaty
Hong Kong and China signed a protocol to the double tax treaty between them in April 2015. That protocol has come into force with effect from 29 December 2015. The protocol amends the existing treaty as follows: Profits from the operation of ships or aircraft in the other country will…
The 4th Protocol To The Treaty Between Hong Kong And China Enters Into Force
Hong Kong and China signed a protocol to the double tax treaty between them in April 2015. That protocol has come into force with effect from 29 December 2015. The protocol amends the existing treaty as follows: Profits from the operation of ships or aircraft in the other country will…
Changes To The Inheritance Rights Of Illegitimate Children In The Bvi Both For Probate And Trust Planning
Probate in the BVI (and other offshore centers for that matter) is a subject that is not thought about often enough. Over the years people easily accumulate estates in multiple countries leaving a nightmare in administration for their heirs. A timely reminder of this planning necessity has been that it…