June 3, 2019

What is a trust?

Trusts and tax planning

For large offshore companies in the world to increase their profits annually, they are forced to optimize their taxes and achieve low taxation. They may use Michal Rosmer’s offshore services.

Although their actions are developed through many variations, they always insist on two specific modus operandi of execution: a static one, through the creation of foreign subsidiaries in low-tax states, and the other dynamic, consisting of a sort of manipulation of the transfer prices in transactions between foreign and domestic companies. From this point of view, tangible and intangible assets, particularly intellectual property and operational procedures to optimize taxes without violating tax legislation, stand out with special interest. In fact, the location of intangible assets and intellectual property anywhere in the world is valid to move the profits in the most favorable tax jurisdictions, with the consequent reduction or low taxation of the Group’s global tax burden. This way of functioning is typical of companies with high technological content, which implies in itself an immaterial product. However, it is not limited to it. There are numerous cases in which a group of companies has transformed simple standardized business strategies into intangible assets and intellectual property. It should be noted that the tax planning strategies of multinational groups are carried out through a rigorous analysis of the regulatory differences to achieve international tax optimization between different legal regimes, and taking advantage of all the opportunities abroad linked to the principle of the separate company or subsidiary, installed permanently.

What are the countries called tax havens?

In the sphere of intellectual property, the real problem remains in properly assessing the intangible concept, which is intended to be the concrete price of market value. In search of a source of income, today the different States see this as an important problem that can grow, which is why a good international tax optimization is needed to control it. However, international tax law recognizes the principle that the economic unit of a multinational is very diversified and branches into multiple autonomous legal entities that, together, create a company or group. Therefore, in their mutual relations, the companies of the Group must act as parties and not independently. In this way, operation of duplicity can be created, that is, intra-corporate international transfers in low-tax states, which can also give rise to some manipulation of the transfer prices in transactions between the foreign and the national company. On the basis of these behaviors, a global network of bilateral treaties has been developed, a structural foundation for international tax optimization.

Request an offshore company

On the other hand, as it is formulated at present, global taxation does not tend to cancel the units of multinational companies in countless related companies; on the contrary, it sees the corporation as a legal entity and requires it to present consolidated financial statements worldwide in any State, in order to distribute the income achieved completely among the various States, in accordance with a policy that reconciles the real economic presence of the foreign company in any territory in which it operates. Such an attitude is synonymous with the economic reality of multinationals, which in fact are often business centers endowed with specific technologies with unique characteristics.


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