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13 Aug 2003 - United Kingdom International Headquarters Company (IHC)

MONACO CORPORATE SECRETARIAT
International tax planning

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United Kingdom - International Headquarters Company (IHC)

INTRODUCUTION
A U.K. company which has 80% of its share capital owned by UK non-residents will qualify as an International Headquarters Company (IHC).

Under certain circumstances an IHC may not pay UK corporation tax on income dividends received from a subsidiary, under other circumstances it may not be subject to UK capital gains tax on the sale of shares in its subsidiary.

TAXATION
* Providing the subsidiary company has borne tax on its profits tax at a rate at least equal to the UK corporate tax rate (21% to 31%) then the income dividend received by IHC from the subsidiary is completely free of UK tax

* Providing the IHC is part of a trading group of companies (or is itself trading) and it has owned for more than one year at least 10% of the share capital of its subsidiary company - which is a trading company than there is no UK capital gains tax payable on the disposal of the shares of its subsidiary

* There are no withholding taxes paying either income or capital gains dividends paid from an IHC to any company situated anywhere in the world including offshore company.

* If there is a need to be part of a tax treaty network the U.K. has one of the largest tax treaty networks

* There is no capital duty on the issue of shares. There is stamp duty on share transfers of ½%.

CORPORATE
* There is no minimum capital requirement. Bearer shares are permitted however it is preferable to use registered shares in the case of an IHC. The share capital can be in any currency. There is a public registry of shareholders. The minimum number of shareholders is one.

* The minimum number of directors is one. Corporate directors are permitted. There is a public registry of directors. Directors can be resident anywhere in the world but to maintain the IHC status should be UK resident or resident in a tax haven. A Company Secretary must also be appointed.

* In practice, it takes about 10 days to incorporate and obtain the corporate documents. Same day incorporation is possible upon payment of a special fee.

* There are no exchange controls in the UK. Bank accounts can be opened in any part of the world.

COMPLIANCE
* All UK companies must prepare a balance sheet and accounts each year which may have to be audited if turnover, staff or assets are over (a quite high) threshold.

* The accounts must be approved in an Annual General Meeting and filed each year.

For further information
Please contact :
Derek R. SMITH of M.C.S
Email: assetprotect@libello.com
Tel +377 9797 6230
Fax +377 9797 6233

While every effort has been made to ensure that this information sheet is accurate and up-to-date we cannot be held responsible for any errors or omissions.
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