offshore, non-resident
  Thursday, 9 September 2010

     In this section we are going to provide several examples illustrating cooperation between resident and non-resident companies in transactions with "intangible" goods, i.e. management services, consultancy, and dealing with financial instruments.

There are certain instances when large companies lack a proper mechanism for settling accounts with their trade and other agents, usually physical persons, for services rendered. This is normally caused by their inability to pay out remuneration to physical person. In such cases, it may be useful for the agent to found a non-resident company, so that the resident enterprise can transfer the proper sum to its account by using, for example, a standart agreement on the provision of marketing services.
By escorting or forwarding goods for import or export belonging to another company (including the onshore, i.e. the resident company), and ensuring its shipping, safety or insurance, the non-resident company (even if it does not buy or sell the goods itself) takes a certain share of the total profit for itself, which is in this way exempt from taxation.
If you are an entrepreneur, a bank manager or manager of some other entity involved in financial operations, the non-resident company may take the major share of the profit from currency conversion operations, either by taking a direct of indirect role in said operations. It can also become the lending agent for your financial operations, appropriating to itself the major part of profit from the issued loan.
The non-resident company can provide legal, information or management services to the resident company from abroad, thus decreasing the taxable base of the resident company. In this case, there tax is liable at source on the payment (i.e. in the country of incorporation of the resident company), but this tax may be minimal or even zero, if a double tax treaty has been concluded between the two countries.
 
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