Dynamic Tax Planning: Ring-Fencing Management And Control

A. INTRODUCTION

It has now become crucial that actual substance is infused into the operations of international business Companies in order to safeguard their tax residency. This need has arisen from the worldwide financial crisis that has led Governments to seek for mechanisms to protect or increase their tax base outside their jurisdictions by disputing the tax residency of companies in countries that are considered as low tax jurisdictions.

In this publication, we shall examine in depth the reasons why considering substance has become more crucial; what are the common mistakes made by the foreign investors whereby rendering the tax residency of their companies open to attack by foreign jurisdictions; and what additional protective measures are to be considered in order to have a tax viable and beneficial structure for many years to come.