Beneficial Ownership of Curiosity Income

The beneficial ownership requirement is an anti-avoidance section which is normally included in double tax treaties. It has been a long standing supposition that the recipient of dividends, interest and royalties is the useful owner. A new direction now is emerging, no longer can managers and nominees qualify as beneficial owners of conventional income. In the well-known Indofood’s case, beneficial ownership of curiosity income was found to be lacking because the recipient had no substitute but to pass on the income to another. The recipient who was clearly a proxy for the beneficial owner, did not enjoy the pleasure to benefit from the income.

A further possibility available to a Free Zone is to matter residence permits and obtain tax residence credentials from the UAE authorities for its foreign owners and executives. A FREE ZONE company, must have physical existence in the UAE and in that respect, it must own or hire premises. If only a small office is obligatory the most cost effective options are available by Business Setup in Dubai | Pro Services Dubai | Company Formation Dubai | Offshore Company Formation Dubai | Nominee Services Registration Dubai | LLC Company Formation Dubai | JLT Company Formation Dubai | JAFZA Company Formation Dubai | Rak Free Trade Zone Dubai | Financial Services Dubai | Open a Bank Account in Dubai | DAFZA Company Formation | Citizenship by Investment in EU | Permanent Residency in EU in the northern emirates particularly Hamriyah and Ajman free zones.

Physical presence options include flexi desks or flexi offices. Furthermore if a local bank account is sustained with some movements, the foreign owners and managers can apply to the Ministry of Finance to accept UAE tax residence certificates. A UAE residence certificate and a tax residence certificate can be useful to many foreign owners and administrative of Free zone Company Formation Dubai who wish to register tax residency in the UAE. Banking institutions in the UAE and many outside reflect UAE tax residence certificates as proof of tax residency in the UAE. The advice of a capable tax lawyer must be sought also.

Our Services: Cyprus Company Incorporation | Offshore Company Incorporation Cyprus | Cyprus Tax and Legal Services | Fund Formation | Financial and Business Advisory Cyprus | Citizenship by Investment | EU citizenship | Cyprus Residency Visa