Shanker Iyer Shanker Iyer & Co 30 th May 2008 NEXIA INTERNATIONAL – TAX CONFERENCE Cross Border Transactions.

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Presentation transcript:

Shanker Iyer Shanker Iyer & Co 30 th May 2008 NEXIA INTERNATIONAL – TAX CONFERENCE Cross Border Transactions

Agenda  Case Study I  Case Study II  Questions

1 Case Study I

Case Study – 1 Singapore Company (Singapore Co.) Liberian Holding Company (Liberian Co.) 100% Share ownership Loan Loan = 30% of (Capital + Loan) 2 Switzerland Cos. (Swiss Co.) 100% Share Ownership i.e. 70% of (Capital + Loan) Dividend Interest Dividend Interest

Case Study – 1 Singapore Company (Singapore Co.) Liberian Holding Company (Liberian Co.) 100% Share ownership Loan Loan = 30% of (Capital + Loan) 2 Switzerland Cos. (Swiss Co.) 100% Share Ownership i.e. 70% of (Capital + Loan) Dividend Interest Dividend Interest  Without Singapore SPV - Swiss distribution WHT 35%  Singapore tax treaty benefits  Singapore territorial tax system  Singapore foreign income exemption scheme  Singapore’s one tier dividend system

Dividends Case Study – 1 Singapore Company (Singapore Co.) Liberian Holding Company (Liberian Co.) 100% Share ownership Loan Loan = 30% of (Capital + Loan) 2 Switzerland Cos. (Swiss Co.) 100% Share Ownership i.e. 70% of (Capital + Loan) Dividend Interest Dividend Interest

Case Study – 1 Singapore Company (Singapore Co.) Liberian Holding Company (Liberian Co.) 100% Share ownership Loan Loan = 30% of (Capital + Loan) 2 Switzerland Cos. (Swiss Co.) 100% Share Ownership i.e. 70% of (Capital + Loan) Dividend Interest Dividend Interest

Case Study – 1 Singapore Company (Singapore Co.) Liberian Holding Company (Liberian Co.) 100% Share ownership Loan Loan = 30% of (Capital + Loan) 2 Switzerland Cos. (Swiss Co.) 100% Share Ownership i.e. 70% of (Capital + Loan) Dividend Interest Dividend Interest Capital gain

1 Case Study II

Case Study – 1I Marshall Islands (“MI Co.”) Singapore (“Sing Co.”) Netherlands (‘Dutch Co.) Ukrainian Properties Bank Loan Finance US$ 53mn Investment US$ 9mn Investment US$ 62mn

 Singapore tax treaty benefits  Singapore territorial tax system  Singapore foreign income exemption scheme Marshall Island (“MI Co.”) Singapore (“Sing Co.”) Netherland (‘Dutch Co.) Ukrainian Properties Bank Loan Finance US$ 53mn Investment US$ 9mn Investment US$ 62mn Case Study – 1I

Marshall Island (“MI Co.”) Singapore (“Sing Co.”) Netherland (‘Dutch Co.) Ukrainian Properties Bank Loan Finance US$ 53mn Investment US$ 9mn Investment US$ 62mn  Where it went wrong in this structure  One condition to foreign source income exemption : not in favor  “Exemption with Progression” not incentive

Marshall Island (“MI Co.”) Singapore (“Sing Co.”) Netherland (‘Dutch Co.) Ukrainian Properties Bank Loan Finance US$ 53mn Investment US$ 9mn Investment US$ 62mn  Negative Ruling by IRAS  Proper planning and interpretation of law at preliminary stage  Additional cost burden for client Case Study – 1I

Questions