Advantages of Barbados incorporation for ship-owning companies Pete Miller, Partner

Why Barbados works Expanding Treaty network Skilled work force Government support to grow economy with real businesses Great place to spend a secondment e.g. from UK Helpful tax regime

New UK rules on taxation of foreign profits Previous mixed rules for dividends UK to UK dividends exempt Foreign to UK dividends taxable with credit (imputation) Now all dividends taxable unless exempt Most dividends will be exempt Subject to anti-avoidance rules! UK Non-UK £$

Planning opportunities I Set up trading shipping subsidiary in Barbados Operate fully from Barbados (NOT brass plate) Low tax rates for non-Barbados source income Should pass UK CFC rules (exempt activities) Remit profits to UK tax free UK Barbados shipping $

Planning opportunities II Set up insurance subsidiary in Barbados Tax deductions for premiums Barbados reinsures risk Profits remain ‘in the family’ Remit profits to UK tax free UK Barbados insurance $

Planning opportunities III Set up employee benefit trust Takes profits out of company Tax deduction in Barbados No UK inheritance tax liability Funds available for employee bonuses, investment, loan to participators, etc. Outside IHT estate for UK purposes UK Barbados shipping $ Barbados insurance EBT Trustees Employee beneficiaries

Advantages of Barbados incorporation for ship-owning companies Pete Miller, Partner