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Introduction to International Tax Management

Tax is defined by the Oxford English Dictionary as 'a compulsory contribution to the support of the government, levied on persons, property, income, commodities, transactions etc.' The primary purpose of tax is the aim of collecting revenue for the authorities governing a particular part of territory, so that such monies may contribute towards the general expenses of maintaining that society. Whilst the golden rule in tax planning is to 'always pay some tax somewhere', there can be significant differences in the net income that is unprotected, and that which is carefully structured so as to result in the minimum taxation allowed by law. In the words of the English Law Lord Clyde:

"No man in the country is under the smallest obligation, moral or other, so to arrange his legal relations to his business or property as to enable the Inland Revenue to put the largest possible shovel in his stores. The Inland Revenue is not slow - and quite rightly - to take every advantage which is open to it under the Taxing Statutes for the purposes of depleting the taxpayer's pocket And the taxpayer is in like manner entitled to be astute to prevent, so far as he honestly can, the depletion of his means by the Inland Revenue"

To facilitate this process, it is advisable to have a basic knowledge of the fundamental concepts of offshore companies and trusts, and interaction of the different elements that make up a sound tax solution. This guide is designed as an introduction to international tax management, also giving some actual case examples. Clearly this material is not intended as an exhaustive explanation of a standard range of products, since all tax and other benefits arising out of offshore entities are determined by the particular aspects of the country of residence of the beneficial owner, its respective anti-avoidance legislation, and any third country with which the structure comes into contact.

   
 
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