Multiple Advantage of Multi-Jurisdiction Structure

When it comes to planning investments and wealth, there is no ‘one-size-fits-all’. There are as many as 80+ jurisdictions which offer offshore structuring and each one of them is unique in its own way. The number and the kind of treaties that each jurisdiction enjoys with partnering countries is never the same and neither is the client’s need.

It is at these times that one should consider making use of more than one jurisdiction as part of the structure.

Whether it is international trading, assets across borders or investments that one looks at, the very fact that it involves more than 2 or 3 countries leads to different requirements that need to be met. And depending on the source of the investment and the destination the usage of more than one jurisdiction would come into play.

Let us consider an example:
Mr. Zhang Wei a successful medical equipment supplier in Hunan province in China is exploring the possibility of trading his goods in say, Uganda. While he already has a Hong Kong company ‘Zhang Wei Medeq Pvt Ltd’, which has helped him creating a market in rest of Asia, he is unsure of Africa.


This is all but a simplistic solution to look at a multi-jurisdiction structure which is absolutely compliant with international regulations.

 So what are the reasons to consider a multi-jurisdiction structure?

  • Books are maintained separately. One’s profit / loss doesn’t affect another leading to better valuation of each entity
  • Each entity has the potential of its own to create newer markets
  • Jurisdictional advantages like investment protection
  • Simplified accounting depending on the kind of entity created in each jurisdiction
  • Asset protection wherever applicable
  • A variety of products available to choose; from simple trading / holding companies to Trusts / Foundations or Funds based on the need.
  • Incidentally, these structures can also prove to be highly tax prudent

At Abacus Seychelles, we believe in working closely with our clients in creating structures which are compliant, simple and still provide you with the best solution for your given situation across multiple jurisdictions through our network of associates.

Apart from Seychelles, we can provide solutions in other renowned jurisdictions including Mauritius, Hong Kong, Cyprus, Dubai, Singapore and many more.

We would be happy to assist you in your multi-jurisdiction requirements. Please do connect with us with your requirements on and we would be happy to take a call with you.

Cyprus – International Business Solutions,Wealth Planning and Asset Protection,Fund Solutions

Cyprus – Seychelles collaboration through the double taxation treaty – By Anuj Sharma

The Cyprus-Seychelles Double Taxation Avoidance treaty came into force on November 2, 2006.

The two countries however, share a history which goes well before that.
There is a closeness that has always existed between Seychelles and Cyprus on the basis of

•     Their geographical features – their small size, location amidst several continents, flexibility to adapt to changes and a vast coastline

•     Their historical past (both have faced turbulent past and survived invasions. And both have been part of the Commonwealth after their independence in recent times. Mr. Makarios the Archbishop was exiled to the Seychelles in 1956. He was released from exile a year later, although he was still forbidden to return to Cyprus. He went instead to Athens and worked hard to achieve freedom for his people.

•     Their economy: is young and progressive, they have survived on tourism, shipping, fishing, agriculture etc. But now in order to compete and outperform their counterparts they have opened the gates of their economy for foreign investments. Through introduction of new laws, simplified procedures, fiscal incentives, inward investment opportunities and DTA treaties and many more changes, they intend to emerge as new super power jurisdictions.

Seychelles Special License Company (CSL) :

After Seychelles success with the IBC (with over 130,000 companies on register), Seychelles has diversified and now provides an excellent wider scope of vehicles for more efficient tax structures involving Protected Cell Companies and Limited Partnerships and the use of Special License Company to utilize the ever-increasing network of double taxation agreements.

In this article, we shall examine the Cyprus-Seychelles Double Taxation Treaty and how it has opened avenues for accessing investments into EU and CIS countries.

A Special License Company is a resident company with access to double taxation avoidance agreements and is liable to tax at a marginal rate of 1.5% on worldwide income. It is exempt from withholding taxes on dividends, interest and royalties. It is also exempt from stamp duties on property transfers, share transfers and other business transactions.

The Company needs to submit annual returns and financial statements to the Seychelles

International Business Authority within 90 days from the end of the financial year.

The Cyprus-Seychelles treaty:

The Double Taxation Avoidance treaty has been in force for well over 7 years now.

The key features of the treaty are:

Dividend, Royalties and Interest exemptions for Cyprus Company:

Dividends, interests and royalties derived from Seychelles by offshore entities are tax exempt. According to the treaty there is no withholding of tax on repatriated dividends, and repatriated interests. However this provision shall not apply if the Special License Company (CSL) has a permanent establishment in Cyprus.

DTAA provides for 5% on repatriated Royalties; similarly this withholding of tax rate shall not apply if the CSL has a permanent residence in Cyprus.

When a Seychelles resident is a recipient of dividends from a company, which is resident of the treaty country like Cyprus, the Seychelles recipient is entitled to a tax credit which shall take into account the tax paid by the resident company (Cyprus), which is the treaty country paying dividends in respect of the profits out of which the dividend is paid.

Capital Gains Exemption:

Double taxation is eliminated by the credit method, i.e. the taxpayer’s country of residence will grant a credit for taxes paid in the source country. DTAA states that gains made from sale of shares by CSL holding shares in Cyprus company which derives its value from immovable property, may avoid Cyprus capital gains if the value of the gains is less than 50%.

Any capital gains made from sale of shares by a CSL holding shares in a Cyprus company is taxable in Seychelles if the permanent establishment is in Seychelles.

Tax on Income:

A CSL is liable to 1.5% Seychelles tax on its worldwide income. DTAA provides that any withholding tax paid in Cyprus can be credited against the 1.5% Seychelles tax payable by the CSL and where the Cyprus tax exceeds 1.5% the Cyprus tax credit will discharge all tax liability in Seychelles.

Examples of Cyprus-Seychelles DTAA application:

As Cyprus is now part of European Union (EU), Seychelles can access EU markets easily through Cyprus-Seychelles treaty.

While successful implementation of treaty structures is dependent on a wide variety of issues, often relating to matters such as anti-avoidance provisions, controlled foreign company  and  management  and  control  tests  and  provisions,  transfer  pricing,  thin capitalisation, participation exemptions and on any changes in tax regulation; a few examples below clearly demonstrate the beneficial applications of the Cyprus-Seychelles DTAA.

1.  Investment in Countries where Cyprus has a treaty:

Many large corporations are interested in investing in countries where no double tax agreement exists between the countries. In this case, an intermediary company is established in a jurisdiction with a suitable treaty. For instance, Cyprus has an extensive double tax treaty network with many Eastern European countries like Romania, and the use of Cypriot companies for inward investment into these countries provides a tax efficient conduit.


2.  Investment in Seychelles:

The two scenarios below contrasts the investment made into Seychelles directly and through

Cyprus treaty and help analyse their respective tax treatment.

Scenario 1:

When the overseas company directly makes an investment in Seychelles, the withholding tax in Seychelles will be 15% on dividends and 10% on interest on investment made in Seychelles


Scenario 2:

When the investments are made in Seychelles by way of loan or capital through the Cyprus route, the payouts made from Seychelles in form of dividends or interest is tax free due to DTA Treaty with Cyprus and vice versa.

The illustration below shows investment coming into Seychelles from an Overseas Company through Cyprus route in form of Loan or Capital and the payouts received in form of dividend or interest from Seychelles is treated tax free due to DTAA with Cyprus.


3.  Dividend or Royalty Exemptions for a Cyprus Company:

A Seychelles company has made investments in countries (India, CIS countries, countries in or out of EU) with whom Cyprus has treaties.

As the illustration below shows payouts (1) in form of dividend and interest received by Cyprus Company will be at 0% or at a reduced rate of tax due to the DTA of Cyprus with that country. And payouts (2) in form of dividends or interests received by Seychelles Company will have 0% withholding of tax as there is no deduction at source in Cyprus on payouts made to a non-resident.



It is expected that Cyprus-Seychelles collaboration which has flourished through tourism, and of use of Seychelles IBC as a holding company for several Cyprus structures and vice versa till now, will get another dimension through use of the double taxation treaty. Seychelles will hope to access the EU as well as CIS markets through the Cyprus treaty.

The possibilities for collaboration will increase further with the recent launch of Mutual Funds in Seychelles. The Cyprus companies can incorporate mutual funds in Seychelles for investments to and from EU and CIS countries, as well as to reach out to countries like in South-East Asia where Seychelles has favorable double taxation treaties.

Taking your Business Global and to Global Funding

John Bickett is a serial internet entrepreneur based in Europe; with success of multiple businesses to his credit. His lines of businesses range from local cab reservations to restaurant reservations and event tickets resell to domestic holidays though the internet and mobile applications. All these businesses were doing fairly well and it was time for John to take his entrepreneur skills global.

He recently got an App built locally, that aids in managing the expenditure for living together roommates. The app lets a group of friends who share a common roof; keep track of the expenditure and split the costs among them. Considering that the youth would be biggest set of users and the biggest target for B2C advertisers; the mode of revenue was planned to be though in app display ads.

Owning to the possibility of universal consumption, that is; an app that can be used by users across the globe he was sure to garner interest from the global investor community. Basis initial discussions with a few potential investors he came across the option going offshore.

He learnt that going offshore for the business has benefits beyond saving up on taxes. Going offshore had several benefits like quick set up, low admiration costs, minimal annual paperwork; Offshore jurisdictions have minimal or close to nil taxation on worldwide income. Several offshore jurisdictions also enable listing in their stock exchanges; which can be cumbersome and may require heavy investments in mainland countries. They also have favorable Intellectual Property Rights and Transfer laws

Critical among these advantages, from an Investor perspective was the cost saving on tax that the potential investor would make if the investment is made in an offshore company. Offshore companies have simplified legal framework, optimized tax structures and enable quick transactions while keeping exposure of information limited.

Going offshore would be a win-win situation for John and his potential investors. They get taxed lesser than general. Offshore jurisdictions charge taxes in the range of nil to 17 % while mainland countries charge corporate tax in the range of 30%-45%. Add to this the benefits of acquiring technical and business inputs from a global expert pool.

After much deliberation they set up the company in Hong Kong to attract investors from China and APAC. Today John’s app “Roomie” has investments to the tune of USD 500 million. Having understood the value and advantage of going offshore; John is today in the process of moving his other business offshore and expanding their reach to Europe and beyond.

Like John there are many innovative entrepreneurs, who are not conceptually sound of finances or international laws but want to take their businesses global and get global funding. All that is required is a little understanding and a credible international law consultant to help take your business Global.

If you have queries do write to us HERE or If you wish to discuss your specific case, fix your FREE DISCUSSION appointment HERE

Malta Citizenship by Investment Program

Malta Citizenship by Investment Program

Malta is the largest of the three major islands that constitute the Maltese archipelago. Malta is in the middle of the Mediterranean Sea directly south of Italy and north of Libya. The Maltese climate, culture, history and lifestyle make Malta one of the most attractive places to live in Europe. This coupled with Malta’s attractiveness as a business hub and its competitive tax system elucidates Malta’s rising popularity with the internationally mobile citizens.

Malta Citizenship by Investment may be granted under an amendment passed in November 2013 to the Maltese Citizenship Act, Chapter 188 of the Laws of Malta. Malta’s citizenship by investment program requires individuals to make a financial contribution and investment in Malta’s social and economic development. The contribution can be in the form of

  • A non-refundable contribution of €650,000
  • An investment in Maltese Government bonds €150,000 (no ongoing top-ups required)
  • The purchasing or renting property in Malta (€350,000 / €16,000 per year for 5 yrs).

Benefits of Malta Citizenship by Investment

  • Rights of EU citizens including the right to move, reside and live freely in any of the 28 EU Member States.
  • Only approved investment program by the European Union.
  • Visa free international travel to over 160 countries including the UK and the USA
  • Citizenship itself is tax neutral (tax advice should be sought)

Grounds for Refusal of Malta Citizenship by Investment

  • Providing false information
  • Having a criminal record or being subject of a criminal record
  • Potential national security threat
  • Likely to cause disrepute to Malta
  • Denied a visa to a country

Grounds for Revocation of Malta Citizenship by Investment

Citizenship was acquired by means of fraud, false representation or the concealment of any material fact or such citizen has shown himself or herself by act or speech to be disloyal or disaffected towards the President or the Government of Malta or such citizen had engaged, unlawfully traded or communicated with an enemy or been engaged in or associated with any business that was motivated by willingness to assist an enemy in that war.

Malta Citizenship Application Process

  • Apply for Residence, 1 year in advance
  • Formal Application by Accredited Person
  • Identity Malta confirms if documentation submitted are formally in order
  • In Principle Approval
  • Formal Request for Contribution
  • Deadline for paying balance on contribution.
  • Final Compliance: Provide evidence of Property Purchase / Rental & Investment.
  • Issue of Certificate of Naturalisation (maximum time to issue: 2 years). Subject to: Oath of Allegiance, 1 Year residence.

For detailed information on fees, processes and timelines write to us at

Disclaimer: Information given in this brochure does not constitute as advice on any particular matter, AM Abacus group is not responsible for any action or inaction taken on the basis of above information.