What sort of services can we offer?
Whilst we do not provide tax or legal advice, we do have access to a number
of specialist advisors in this area and we are able to assist clients in
the following areas:
UK non-residents – expatriates
Isle of Man companies and trusts are less viable for individual UK residents
but there are circumstances where they can still be of value. For instance
where a UK national is considering emigrating or working abroad an Isle
of Man company/trust may be a useful vehicle for property ownership, employment
or to provide protection for assets. Isle of Man companies and trusts may
be of particular interest where a client believes he/she will obtain a financial
gain from say the sale of a business or from the commercialization of a
franchise, royalty or patent. By selling the right at an arm’s length
basis to an offshore structure and then moving residents and domicile abroad
before commercialization the client may realise gains in an optimal tax
environment (provided he remains out of the UK for over five years). A client
may also benefit from a form of National Insurance planning by using an
Isle of Man employment company. This is difficult to apply in the UK but
is still viable for some clients when posted to jurisdictions with similar
NI legislation.
UK Non-domiciled clients
Foreign nationals (non domiciles) living in the UK may be able to enjoy
a special tax status and can often establish a favourable tax structure
to ensure avoidance of the incidence of UK Income tax, CGT and Inheritance
Tax on their world-wide assets not remitted to the UK.
We have good access to professional legal and tax advisors who can assist
our clients in establishing the most appropriate structure to ensure they
achieve optimal tax efficiency in this area.
Companies and Intermediaries
Certain structures are still relatively effective for commercial purposes,
for instance UK property owning for investment purposes. Where a company
has been set up as a collective investment scheme and each UK holder holds
less than 10% (to avoid attribution of gains under s13 TCGA). This is still
a useful structure to avoid CGT, especially so where there are foreign investors.
Also IOM structures may be of benefit for pension arrangements which
have favourable tax treatment for based clients.
IOM structures are also still useful for certain types of international
transactions. VAT planning is possible for super-yachts and aircraft, VAT
triangulation on trading transactions outside the UK and shipping benefits
under the special regime here providing a more attractive alternative to
tonnage tax in certain circumstances.