In a judgment which is likely to have wide-ranging implications for local companies subject to the '60/40 rule', the Privy Council recently held that local companies may confer on non-Bermudians "de facto control by commercial arrangements", provided that non-Bermudians have no control over the manner in which directors and shareholders vote.
The Income Tax (Substance Requirements) (Implementation) Regulations 2018, as amended, came into effect on 1 January 2019 and apply to accounting periods commencing on or after that date. The new economic substance requirements apply to certain Guernsey tax-resident companies and have been passed in order to comply with the EU Code of Conduct Group on Business Taxation. This article summarises the current position relating to the substance requirements for fund management companies.
Anyone that has been refused planning or building permission or disagrees with a condition that has been attached to a planning or building permission or anyone that owns or occupies a building or land where a building, place or tree has been listed can appeal against a planning decision. However, Jersey planning appeals raise numerous questions regarding costs and the appeal process.
This article addresses notable recent developments regarding the provision of private client services in Liechtenstein, including regulatory changes and case law. Of note is the abolition of the distinction between offshore and onshore companies by the introduction of a uniform corporate income tax rate of 12.5%, which, among other things, made Liechtenstein companies more attractive internationally.
When planning for the transfer of wealth to the next generation, families and their advisers must consider the context in which it will take place. On current trends, planning for changes of domicile and to counter both electronic security risks and bouts of mental illness are likely only to increase in future importance.