A capital introducer was looking for a way to market an institutional fund to include sufficient margin to pay their distribution network.
A segregated portfolio share class was created under our existing Cayman segregated portfolio company Master fund which provided a low cost solution to both the set-up and the ongoing costs. The cell invested into the institutional fund with a management fee applied to pay the distribution network. Using the cell approach, the start-up costs were minimal and the fund was able to mirror the underlying funds' performance.
An investment manager wished to manage their own assets in a fund structure and benefit from tax deferral. Any income and gains not distributed would be taxed as the fund and it's assets would be deemed to be controlled by the investment manager.
Combining our Fund, Corporate and Tax Consultancy services and using our Shared Fund Services, a segregated portfolio share class was created under our existing Cayman segregated portfolio company master fund. The fund share class opened its own prime broker account which was advised by a newly incorporated fund manager with responsibility for the trading strategy. The newly established fund management company was owned by the investment manager who took a market rate fee for the services provided, whereas the master fund was manged by our regulated fund manager. Segregating the place of effective control and management of the fund from the investment manager and using our shared corporate services to ensure substance, we were able to ensure that the investment manager dictated the strategy, yet benefitted from tax deferral.
The client, a French national, is planning to move back to France having left 15 years earlier. He was a successful fund manager in London and recently sold the business. Prior to moving back he wishes to plan the family’s financial affairs, with a focus on tax deferral and succession tax planning.
The French tax code provides for various tax exemptions for family businesses. By setting up a foreign holding company with multiple share classes, where the ownership was divided between life interest shares and bare ownership shares including a management share class, we were able to offer a flexible succession tax planning vehicle. Tax deferral was achieved by the holding company owning its investment assets via a mutual fund. Access to regular income without the need to redeem from the fund was achieved by lending to a securitisation vehicle that held debt issued by the fund.
A Singapore resident wished to purchase a residential investment property in U.K. to let. They were looking for a tax efficient way to hold the property.
A non-resident individual owning U.K. residential real estate until recently was permitted to deduct the cost of borrowing from the rental income and any gains upon disposal of the property were tax exempt. With the change in law we set-up a foreign holding company to own a U.K. company that ultimately owns the residential property. The U.K. company then applied for a mortgage. The mortgage interest was tax deductible, the double tax agreement between the jurisdiction of the holding company and the U.K. provided for right to taxation of the gains to be belong to the jurisdiction of the holding company. By subsequently transferring the shares of the holding company to a suitable structured foreign pension, we were able to mitigate any inheritance tax liabilities.
A Hong Kong trustee wished to outsource the administration of an occupational retirement scheme to a pension administrator with experience in administering both qualifying and exempt pensions whose tax liabilities included foreign source income and gains from jurisdictions with a double tax agreement with Hong Kong.
Argyll Management Services used its in-house knowledge to set-up procedures to administer a number of jurisdictions to qualify for tax relief. Individual tax opinions were obtained for many of the jurisdictions to clarify some of the procedural requirements.
A Belgium national moving to the United Kingdom wished to minimize their tax exposure on certain non UK investments.
For UK tax purposes the Belgium national was deemed non UK domiciled. A trust was settled to hold the assets with the trustees ensuring that capital and income were segregated. This allowed income earned to be used to invest in non-UK assets tax free.
A client with a large expatriate workforce across Africa, Latin America and Asia wished to provide their staff with a pension arrangement that was transportable and tax efficient should they move to Europe or USA.
A qualifying occupational Hong Kong pension was established. It was structured so as to qualify under the various double tax treaties Hong Kong has with the OECD countries and registered with the appropriate authorities. The employer was able to contribute to the pension on behalf of their staff from a Hong Kong subsidiary. The staff could now manage their own pensions and take advantage of Hong Kong's tax treaties that give Hong Kong the exclusive right to tax the benefits and its relatively low tax rates.