Nominees and Substance (Mind,Management & Control Rules)
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- čas přidán 12. 05. 2021
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In the world of international tax planning the concept of substance has been rising in importance at the same time as the popularity of nominee directors and shareholders have been decreasing.
Surprisingly then, some firms and lawyers out there are telling people "you need a nominee director in order to have substance".
Today we're going to debunk some myths and explain to you what constitutes substance, what doesn't constitute substance, what nominee directors are good for and what what are not good for.
We'll also play a little into the corporate residency rules pertaining to the mind, management and control of a company.
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as you don t leave the keys of your apartment or house to a completely stranger , I cannot think any other structure except a shell-paper company that is " run " by a nominee
Nominees no but there are licensed fiduciaries and trustees who do so legitimately. But it's hard to argue to a tax official that someone who doesn't have signing authority on bank accounts is exercising "management and control"
Very helpful as always.
Happy to help!
In case you have any suggestions, feel free to leave them below
Amazing video as always, Mike. Thank you for clearing this up. I am still waiting for the Australian one.
Thank you for the support!
Added to the list, stay tuned! :)
great stuff! really enjoying learning from you. will be booking a call with you sometime in the future
Thank you! Looking forward to our call!
In the meantime, feel free to share what you'd like to see on my channel
Can you list 10 countries that dont have management and control rules?
Great video.
Quick question: Lets a HNW person avails of a lump sum taxation program ie Italys. So all he pays is 100k in tax for everything. If he were to also effectively control ie be a director of a foreign / offshore company, would that company be liable for Italian corporate tax as he would personally be tax resident in Italy due to CFC rules?
I'll do a video on the Italian lump sum taxation but yes their role could result in tax residency, application of CFC rules, or source income for the company in Italy.
@@OffshoreCitizen Great, I look forward to that video.
It is strange. I would of imagined that the majority of people wanting to avail of such a lump sum program would have prominent interests in companies (eg directors or large shareholders) as they would be HNWI's. That being the case one would of thought that the authorities would not go out of their way to inflict tax hassles on the persons non resident company profits.
Not as good as thanking Biden. You should do one for every western leader out there as rather than look at govt spending & becoming more efficient they just think go after HNWI.
😂😂😂👍