INTERNATIONAL
BUSINESS COMPANIES
- Types
of IBCs
Holding
Companies
A holding company by its very definition is a company whose business
it is to hold shares in and to exercise management and control of other
companies. Its uses include the collection of dividends from a subsidiary,
which may in turn be reinvested, free of tax. In the event of the sale
of the shares in the subsidiary to a third party, profits are maximized
there being no taxes payable on such sale.
Personal Investment Companies
The business of this kind of Company is to invest in securities on behalf
of its owners. Its major asset is usually a securities portfolio from
which it will earn profits from trading and dividends in a low tax or
no tax jurisdiction.
Import/ Export Companies
These types of companies are ideal for transfer pricing strategies.
Of course there are several variations to strategies but an illustration
will suffice. Instead of buying inventory from a wholesaler directly,
goods may first be purchased by the offshore company, which in turn
sells the goods to the onshore company at a premium for the service
provided. The majority of the profit therefore remains in the offshore
tax-free company while the onshore company accrues loss chargeable income
and may even become entitled to special tax concessions and/or government
subsidies.
Professional Service Companies
These companies allow professionals to secure their income offshore
as professional fees are paid directly into the offshore corporation,
which company will in turn pay the professional an agreed sum for tax
reporting purposes.
Intellectual Property Holding Companies
The use of this type of company is ideal for a developer or purchaser
of intellectual property. The owner of a design or other intellectual
property when sold naturally shall be entitled to royalties upon its
reproduction. Those rights should be sold to the offshore company, which
will in turn license onshore companies to distribute the same. The offshore
company may then receive the royalties from the onshore companies direct
and the moneys once paid are tax-free.
Finance Companies
A common use of an offshore holding company is to fund a secondary company
through loans in circumstances where the secondary company is located
in a country that allows for the deduction of interest on such loans
as a business expense. This strategy enables a group of companies to
in effect lend money to itself and collect interest income in a zero
or low tax jurisdiction while at the same time allowing the onshore
company to subsidize interest earnings.