Offshore Hsbc Botswana. Numbered accounts

Tax Consultants believe that the Ministry of Finance is very broadly interprets the concept of countries with preferential taxation. In Cyprus, the high tax rate - 10%, in the lists of areas with low tax hit, such as Delaware, but not New York, which is actively used for optimization.

Through transfer pricing companies accumulate profits from offshore traders or registered in offshore zones holdings to profit from the Russian assets, and return it to the country in the form of investment. The state has a whip, and there is a carrot - zero rate of taxation of dividends. While some companies will have to abandon the offshore schemes, these benefits may not be enough to encourage companies to register holdings in Russia. The input threshold is too high, as is typical for Europe exemptions or lgotirovanie not only dividends but also the sale of shares by a company owned by a long period. In addition, the control is easy to circumvent: offshore company will be owned by a holding company in Russia, or will not form a profit - it would be referred to the services of another, totally independent offshore companies. Even with the zero rate on dividends does not make sense to transfer to Russia holding, if the profits accumulated in nizkonalogovoy jurisdiction finds lawyer large holdings. But this may be due to business objectives, such as the need to increase capitalization, or enter the IPO.