Corporate Tax: Residency & Control Insights - Acquarius
Done properly, setting up an international business or headquarter company overseas as part of a wider planning structure remains an attractive and feasible proposition. However, itis not something to be undertaken lightly and there are a number of important areas to take into consideration beforehand. International cross-border tax is an extremely complicated professional field and it is fundamental that those looking to structure their personal or corporate affairs should seek appropriate professional counsel. Indeed, Acquarius’ view is that any such planning should be done properly - or not at all. However, there are some core principles that we will explore in this and future articles on a jurisdiction’s or state’s “right to tax” income, profit or gains. Competing international laws generally accept two very high principles. These are a) the right of a state to tax at source “source taxation” and b) the right to tax based on “residence”. Residence extends to “artific...