CZECH AND SLOVAK COMPANIES WITHIN INTERNATIONAL TAX PLANNING STRUCTURES. PROTTECO TRUST COMPANY LTD ing. Tomáš Chrobák Executive Manager

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1 CZECH AND SLOVAK COMPANIES WITHIN INTERNATIONAL TAX PLANNING STRUCTURES PROTTECO TRUST COMPANY LTD ing. Tomáš Chrobák Executive Manager

2 General information about the Czech Republic and Slovakia former states of Czechoslovakia that split peacefully in 1993, situated in the Central Europe, EU members since 2004,

3 General features of both countries implementation of EU directives + broad net of double taxation treaties, low company formation and administration costs, ready-made companies available, very good image of a reputable EU country never appeared on any blacklist, offer many possibilities for international tax planning and asset protection as jurisdictions not attracting unwelcome attention of tax authorities,

4 Czech Republic typical legal forms LIMITED LIABILITY COMPANY (s.r.o.) JOINT-STOCK COMPANY (a.s.) Requirements as to directors Only individual directors are allowed. Director of a company may be from any country. Requirements as to shareholders Any individual or a legal entity may become a member. Minimum share capital EUR 8, EUR 80, Bearer shares allowed No Yes Obligation to pay-up the capital to a bank account Yes, in case of a new company In case of a ready-made company, the capital has been paid-up already. Bookkeeping requirements Yes Yes

5 Czech Republic typical legal forms limited liability company (s.r.o.) joint stock company (a.s.) no limitations on the country of origin of the shareholders and directors, residence of directors has no impact on the tax residence of the company, tax residency certificate can be obtained easily,

6 Czech Republic tax system essential features place of incorporation or place of effective management in the Czech Rep. = tax residence in the CR, resident individuals/companies taxable on their worldwide income, non-resident individuals/companies taxable on the income earned within the Czech Republic, corporate tax rate 19%, wide network of double tax treaties (77), no CFC legislation, tax losses may be carried forward for 5 years.

7 Czech Republic tax system essential features incoming dividends form part of an overall income of a company and are taxed accordingly, exemption for qualifying EU subsidiaries (10% ownership, 12 months) under EU Parent-Subsidiary Directive 15% withholding tax on outgoing dividends, interest and royalties (exemption of the WHT or lower tax rate under EU Directives or relevant DTT), capital gains forming a part of corporate income and taxed under standard corporate tax rate (19%),

8 Expected changes of CZ tax system of the Czech Republic from 2015 new provisions of the Income Tax Act planned, minimum share capital of a s.r.o. just 0,05 EUR (from 2014), exemption of corporate income tax on incoming dividends and WHT on outgoing dividends, CZ holding company will become a natural alternative to holding companies from Cyprus, the Netherlands, Luxembourg, Malta, Hungary, Slovakia...

9 Important rates from the Czech Double taxation agreements Russia Cyprus Malta Dividends 10% 0% 5% Interest 10% 0% 0% Royalties 10% 10% 5%

10 Slovak Republic typical legal forms LIMITED LIABILITY COMPANY (s.r.o.) JOINT-STOCK COMPANY (a.s.) Requirements as to directors Only individual directors are allowed. Director of a company must be from EU or OECD (he/she must have a residence address in Slovakia OR in other country of EU or OECD). Requirements as to shareholders Any individual or a legal entity may become a member. Minimum share capital EUR 5, EUR 25, Bearer shares allowed No No Obligation to pay-up the capital to a bank account No No Bookkeeping requirements Yes Yes

11 Slovakia typical legal forms limited liability company (s.r.o.) joint stock company (a.s.) not necessary to pay up the share capital to a bank account, bearer shares are not allowed, no limitations on the country of origin of the shareholders, directors must be from an OECD country, residence of directors has no impact on the tax residence of the company, tax residency certificate can be obtained easily,

12 Slovakia tax system essential features place of incorporation or place of effective management in the Slovakia = tax residence in Slovakia, resident individuals/companies taxable on their worldwide income, non-resident individuals/companies taxable on the income earned within Slovakia, corporate tax rate 19%, wide network of double tax treaties (62), no thin capitalization provisions, no CFC legislation, tax losses may be carried forward for seven years.

13 Slovakia tax system essential features from 2004: incoming dividends are not subject to tax, no withholding tax on outgoing dividends irrespective of whether paid to a company/individual and irrespective of the residence of the recepient capital gains forming a part of corporate income and taxed under standard corporate tax rate (19%), 19% withholding tax on interest and royalties (unless a EU Interest and Royalties Directive or DTT applies), 19% withholding tax on certain services.

14 Important rates from the Slovak DTTs Russia Cyprus Malta Dividends 10% 0% 5% Interest 0% 10% 0% Royalties 10% 5% 5%

15 Typical tax structures using Czech or Slovak companies Slovak holding company, Company within an international trade chain (e.g. general supplier of goods to Russia), Companies for asset protection

16 Slovak holding company alternative to Cyprus or Malta less expensive alternative than a Dutch or Luxembourg company dividend income from EU states exempt dividend income from third countries withholding tax and possible reductions (DTTs) dividends paid to the any type of shareholder of a Slovak company not subject to tax

17 Slovak holding company

18 General supplier of goods structure for international trade in goods a special purpose company buying goods from foreign suppliers and reselling to the final buyer the goods travels directly from foreign suppliers to the final buyer margin between the price at a purchase and the price at sale can be kept at a minimum, so far use of a general supplier simplifies the process of obtaining currency control approvals ( passport sdelki ) in Russia

19 General supplier of goods

20 General supplier of goods Advantages does not attract unfavourable attention easier for the importer gateway to Europe Disadvantages cannot be used for a simple tax optimisation in Slovakia (agent agreements etc.),

21 Asset protection assets of an individual transferred under CZ/SK company, special purpose companies, protection of assets against attack, possibility of using more stable legal system, possibility of using the network of investment protection treaties, securing assets for future generations, anonymity of ownership.

22 Conclusion Slovakia and the Czech Republic: both very useful for international tax planning, regarded as stable onshore jurisdictions stable economic and legal environment tax authorities do not target SK and CZ companies

23 THANK YOU FOR YOUR ATTENTION! ing. Tomáš Chrobák Executive Manager Tel.: GSM: PROTTECO TRUST COMPANY Palac Archa, Na Porici 24-26, Prague, Czech Republic

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