May 18, Holding Companies for China Investments Are they still relevant?

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1 May 18, 2016 Holding Companies for China Investments Are they still relevant?

2 Panama Papers Page 1

3 What are Offshore Companies? The term offshore company or offshore corporation is: a corporation or (sometimes) other type of legal entity which is incorporated or registered in an offshore financial center or "tax haven" Although all offshore companies differ to a degree depending upon the corporate law in the relevant jurisdiction, all offshore companies tend to enjoy certain core characteristics: They are broadly not subject to taxation in their home jurisdiction; The corporate regime will be designed to promote business flexibility; Regulation of corporate activities will normally be lighter than in a developed country; The absence of taxation or regulation in the home jurisdiction does not of course exempt the relevant company from taxation or regulation abroad. For example, Michael Kors Holdings Limited is incorporated in the British Virgin Islands, but is listed on the New York Stock Exchange, where it is subject both the U.S. taxation and to financial regulation by the U.S. Securities and Exchange Commission. Page 2

4 Are Holding Companies still relevant? Is there a generic holding structure for investment into China? The answer can be both yes and no. The answer can be no because the design of any holding structure depends on various factors, including: the rate of withholding tax on dividends; how dividends will be taxed in the country of residence of the investing entity; the tax position of the investee company; the bank account opening process; the appropriate gearing level; the industry involved; and the form of the investment. The answer can be yes, however, if the focus is on the location of the investment holding company, and a thorough comparison of the applicable taxes in the various jurisdictions is undertaken (i.e. treaty-shopping). Of course, the local tax implications in the country of the overseas holding company must also be considered particularly in the US. Page 3

5 Considerations needed to be taken on the Holding Company Level Taxes on dividends and capital gains; Withholding tax when the holding company pays dividends to its shareholders; The effective corporate tax rate; Tax on distribution proceeds when the holding company is liquidated; Stamp duty that may be applicable when the shares of the holding company are transferred; and The tax treaty network of the jurisdiction in which the holding company is located. Page 4

6 Considerations needed to be taken on the China Company Level Is the Holding company a resident or a non-resident? According to the State Administration of Taxation (SAT), the presence of the following factors indicates that a non-resident may not qualify as the beneficial owner: the non-resident transfers most (more than 60 percent) of its income within 12 months to residents of a third country; the non-resident has no or only minimal business activities other than the holding of the property and/or rights from which the income is derived; the non-resident s business in terms of assets, scale of operations, and personnel is not commensurate with its income; the non-resident has no or nearly no rights of control or disposal over the owned assets or rights generating the income; and the country of the non-resident either imposes no tax or imposes tax at an extremely low effective rate. Page 5

7 Considerations needed to be taken on the China Company Level Does the Holding company have Economic Substance and Commercial Substance? Who are the shareholders and where are they based? Who are the directors and is someone appointed as a local resident director? What is the turnover of the Holding company? Is their turnover? Does the company have headcount and if yes, who? Do transactions run through the company and if yes, what types of transactions? Page 6

8 Bank Accounting Openings in the Holding Jurisdiction and in China Page 7

9 Main Jurisdictions Investing in China Main Investing Countries 2014, in % Hong Kong 71.7 Singapore 4.9 Taiwan 4.3 Japan 3.6 South Korea 3.3 USA 2.2 Germany 1.7 UK 1.1 Source: Invest in China Last Available Data Page 8

10 Comparison Chart Column1 Hong Kong Singapore Luxembourg Ireland Cayman Islands British Virgin Islands Delaware Public Filings Directors Shareholders Yes Yes Yes Yes No No No Yes Yes Yes Yes No Optional No Beneficial Owners No No No No No No No Annual Filing Requirements Annual Return Audited Accounts Government Costs Min. Annual Statutory Tax Profits Tax Rate Individual Income Tax Rate Value Added Tax Yes Yes Yes Yes Yes No No Yes HKD 555 (USD 71.54) Yes, unless revenue is under million SGD (must do unaudited) 20 SGD (USD 14.87) 16.50% 17% Yes Yes No No No 0 EUR 250 USD 600 USD 350 USD % for Luxembourg City (as LXB has a municipality tax this may vary in other cities) 12.50% Nil on Foreign income Nil on Foreign income Nil on Foreign income 15% 20% 43.60% 20%-40% N/A N/A N/A No 7% 3-17% 0-23% N/A N/A N/A Withholding Tax No Yes Yes (only on dividends and some royalties) Yes N/A N/A N/A Dividends Tax Tax Exemption Applications No No Yes, 15% Yes, 33%-40% N/A N/A N/A Yes Yes, BUT income cannot be generated or remitted to Singapore Only for subsidiaries if they pay taxes in their jurisdiction Only first 3 years for startups N/A N/A N/A Page 9

11 Comparison Chart Column1 Hong Kong Singapore Luxembourg Ireland Cayman Islands British Virgin Islands Delaware General Basis of Legal System Common Common Civil Common Common Common Common Private Limited Ltd & Private Limited Liability Company Ltd Ltd Liability Company Unlimited Company Exempt BC (LLC) Type of Company (S.a.r.l) Branch Nil (if funds not Nil Tax on Offshore Profits remitted onshore) Yes, normal rate Yes, 12.5% Nil Nil Nil Exchange Controls No No No No No No Timeframe for Establishment 4-5 Days 1 Day 10 days 2-5 days 2 Days 2 Days 1 Day Shelf Companies Available Yes No Yes Yes Yes Yes No Corporate Requirements Minimum Shareholder Minimum Directors Corporate Administration Yes, but under strict No Bearer Shares Permitted laws No Yes Yes No Location of Board Meetings Anywhere Anywhere Anywhere Anywhere Anywhere Anywhere Anywhere Corporate Directors Permitted Yes No Yes No Yes Yes Yes Administration Hong Kong Singapore Luxembourg Ireland Cayman Islands British Virgin Islands Anywhere Local Requirements EUR fully paid 1 HKD 1SGD Paid-Up Capital upon incorp. no minimal req. USD1 USD1 No Minimum Required Registered Office Yes Yes Yes Yes Yes Yes Yes Company Secretary Yes Yes No Yes No Optional Optional Director No Yes No No No No Optional Page 10

12 Comparison Chart Column1 Hong Kong Singapore Luxembourg Ireland Cayman Islands British Virgin Islands Delaware Annual Maintenance Work Company Secretary Yes Yes No Yes No Optional Optional Registered Office Address Yes Yes Yes Yes Yes yes Yes No, but one has to be a Local Director No Yes Yes resident of the EEA No No No Filing of the Annual Return & AGM Yes Yes Yes Yes AR yes ; AGM no AR no ; AGM no No Annual Audit Yes Yes Yes Yes No No No Directors Report Yes Yes No No No No No XBRL Filing No Yes Yes No No No No Annual Filing of Tax Return Yes Yes Yes Yes No N/A for CIT No Annual Filing of Employers Tax Return Yes Yes No No No yes No Page 11

13 Comparison Chart Double Taxation Agreements with China Number None but BVI has concluded and signed 27 tax information exchange 66 agreements With China Yes Yes Yes Yes N/A N/A Yes China Withholding Tax on Interests 7% 10% 5%-10% 5%-10% 10% 10% 10% China Withholding Tax on Royalties 7% 6% 10% 10% 10% 10% 10% China Withholding Tax on Dividends Tax - Holding more than 25% of the shares 5% 5% 10% 6%-10% 10% 10% 10% (holding at least 10% of voting power) Page 12

14 Questions and Answers Thank you for the attention! Now is time for the Q&A Session Page 13

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