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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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