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Agreement on Processing of Personal Data CZ / EN

Gibraltar

  • Gibraltar

    Gibraltar is a British overseas territory, located at the southern end of the Iberian Peninsula at the entrance to the Mediterranean Sea. It has an area of 6.8 km2.

    Taxes

    Companies registered in Gibraltar do not pay Gibraltar taxes, including Income Tax and other property taxes, if they are owned and controlled by non-residents of Gibraltar, do not trade in Gibraltar and their income does not come from business activities in Gibraltar. In addition, there is zero Property Tax, Capital Gains Tax, Gift Tax and VAT. Gibraltar is not a party to any double taxation treaties.

    Gibraltar non-resident company is not subject to taxation in Gibraltar. It is a company based in Gibraltar, owned by non-residents and managed by a director who resides and directs meetings of the board of directors outside Gibraltar.

    Bearer Shares

    Bearer shares are not allowed.

    Intimacy

    There is no requirement to disclose any information regarding the real owner of the company in Gibraltar, and the secret is guaranteed by law. The only way the data on owners can be disclosed is the Supreme Court’s order.

    Director details appear in the public register. However, confidentiality can be maintained by the Nominee Director.

    Company type

    Limited, LTD

    Advantages

    The Gibraltar Business Company will gain a wide range of competitive advantages, including:

    • the political stability of Gibraltar is dependent on the United Kingdom
    • Gibraltar is an associate member of the EU
    • the company needs only one director and one shareholder
    • there is no requirement for the number of directors or shareholders
    • no minimum capital requirement is set
    • there is no requirement for directors or shareholders to attend meetings in Gibraltar
    • stable jurisdiction with a very good reputation
    • companies based in Gibraltar are exempt from local taxes

    Introduction

    Gibraltar is a small peninsula located on the eastern coast of Spain. Its area covers 6.5 km2 and its coast extends to only 12 km; has a 1.2 km long border with Spain. The Gibraltar Strait links the Mediterranean Sea to the North Atlantic Ocean. Gibraltar enjoys a moderate Mediterranean climate. Its highest point is the Gibraltar Rock, which towers up to 426 meters high and is surrounded by a narrow strip of coastal plain. In June 2013, the population was estimated at 29,000. The official language is the English language, although Spanish, Italian, Portuguese and Russian are also spoken here.

    The history of the Gibraltar rock is diverse due to its strategic location. The rock has been under British rule for the past 300 years after the territory was “eternally” transferred to the UK by the Utrecht Treaty. During the nineteenth century, Gibraltar became an impregnable fortress with a prosperous society within its walls. Until recently, the key British military and naval base and British culture influenced most aspects of Gibraltar life.

    Although Gibraltar remains the UK’s dependent territory, it has its own directly elected parliament, and the new constitution approved by the referendum held in 2006 grants Gibraltar more independence from the United Kingdom as regards its internal affairs.

    Gibraltar and the European Union

    Although Gibraltar remains a dependent territory of the United Kingdom and joined the EU together with the United Kingdom, it is not subject to VAT, the Common Agricultural Policy or the EU Common Customs Tariff. However, Gibraltar has made a significant portion of EU financial legislation into its law and may apply the rules governing a single European passport in the field of insurance, banking and fund management.

    Gibraltar has always had a tough relationship with the European Union, and in fact between the United Kingdom and Spain there is sometimes a problem associated with the long-term fate of Gibraltar. One of the longest-running litigation between the EU and Gibraltar has been the Gibraltar tax regime (see below).

    Taxation of legal entities

    It was in Gibraltar that a form of so-called exempted company was created, which was widely taken over by other jurisdictions. The low cost of setting up the company made it ideal for asset and investment holding companies, international sales and sales representatives, especially if the deal was made between two jurisdictions with a high rate of taxation. If the company was granted the exempt company status, Gibraltar was exempted from corporation tax and stamp duty on stamp duty under the Companies (Taxation and Concessions Ordinance) Act 1984 (as amended). If the company was granted an exempt status, it was exempted from Corporation Tax and Withholding Tax on securities transactions under the Companies (Taxation and Concessions Ordinance) Act 1984 (as amended).

    A company based in Gibraltar or a registered office of a foreign company was eligible to apply for a Qualifying Company on terms that were substantially the same as those applicable to the exempted company. The eligible company paid a profit tax at a rate agreed with the Financial and Development Secretary and listed on the company’s certificate (1% to 35%). The purpose of such a “design” type of tax arrangement was to allow the company to fall below the lower limit of the home tax regime by paying the necessary minimum amount of tax that allowed the company to avoid the scope of tax evasion rules. In fact, most eligible companies have pledged to pay 5% and 10% of the tax, and this form has become a standard low-tax offshore Gibraltar entity for most major companies.

    The European Union campaign against the so-called “harmful” tax competition has resulted in a ban on these offshore forms of companies, while the regime of eligible companies was abolished in January 2005, and the legislation governing exempt companies gradually ceased to be used by January 2011. However, the newly proposed Gibraltar Taxation a complex series of legal disputes between this jurisdiction and the European Commission, which questioned his right to choose his own tax regime and raised the question of whether Gibraltar did not benefit from unlawful “State aid” under EU rules by having a more favorable set of tax rules than the United Kingdom.

    Based on the first proposed amendment to offshore companies’ forms, all companies, both onshore and offshore, would be subject to a zero Corporation Tax rate, but new taxes based on staffing and property ratios would be introduced, with the upper limit 15% of the profit. The EU considered this a compromise acceptable on the basis that “offshore” companies would still be granted a significant tax advantage because they use smaller premises and have fewer staff than their onshore counterparts. The government subsequently withdrew these proposals and opted for a new corporate tax regime whereby all companies pay a Corporate Income Tax of 10%, excluding energy and service providers who pay a 10% surcharge and are therefore subject to Corporate Income Tax at the rate of 20%. This status was valid on 1 January 2011.

    It seemed that the Gibraltar compromise had fed wolves from the European Commission, and this tax regime has remained virtually unchanged to date. However, in response to the criticism from the EU Code of Conduct Group on Business Taxation, there was some amendment in December 2013.

    Speaking in Parliament on 23 December 2013, Prime Minister Fabian Picardo introduced an amendment and said he was addressing the European Commission’s concerns regarding two aspects of the Gibraltar Income Tax Act 2010, notably as regards the exemption from credit for intercompany loans and income from royalties.

    Later, however, the EU Code of Conduct Group assessed the exclusion of interest on intercompany loans under the Code of Conduct for business taxation as harmful. The European Commission has stated that this measure constitutes State aid. Consequently, Gibraltar abolished this statutory exception with effect from 1 July 2013.

    The Chief Minister also said that the new draft law will abolish the exemption from royalties.

    Taxation of individuals

    For tax purposes, a natural person is either a resident or a non-resident and the nationality is not a determining factor when determining the tax status. A natural person is a “regular resident” if he is present in Gibraltar for at least 183 days in total in one fiscal year or more than 300 days in Gibraltar for three consecutive years. A non-resident means any person who is not a regular resident.

    Gibraltar Tax Law recognizes several deductions and tax rebates, including a tax benefit to a natural person in the amount of GIP 3000, and a GBP 3000 benefit, a benefit to a dependent close to GBP 190, a housing benefit GBP 11 500, child benefit up to GBP 997, personal discount on a GBP 3000 dependent person, GBP 3000 GRP, GBP 3000 preference, and GBP 2000 health insurance rebate.

    There are also deductions for life insurance contributions and interest payments on mortgage loans, and there is also a special benefit for seniors.

    Taxpayers may opt for taxation in Gibraltar according to two different tax assessment systems as follows:

    Based on deduction schemes, the tax is assessed after deducting personal and other gross income tax rebates at current tax rates: the first GBP 4000 taxable income of 15%; other GBP 12,000 taxable income of 24%; and the remainder of the taxable income of 40%.

    An alternative system is a new system based on gross income in which a taxpayer does not apply any tax credits but pays the gross income tax at the following rates:

    Individuals whose gross taxable income does not exceed GBP 25 000:

    to GBP 10,000 taxable income of 6%

    another GBP 7,000 of 20%

    the remaining income of 28%

    Individuals whose gross taxable income exceeds GBP 25 000:

    GBP 17 000 taxable income of 16%

    another GBP 8 000 of 19%

    another GBP 15,000 of 25%

    another GBP 65,000 of 28%

    another GBP 395,000 of 25%

    another GBP 200,000 of 18%

    another GBP 300,000 of 10%

    the remaining income of 5%

    There is no tax on capital income in Gibraltar and the Real Estate Tax was abolished with effect from 1 April 1997.

    Systems of affluent persons

    Given the importance of the offshore sector for the Gibraltar economy, but with a very limited amount of local labor, the government has traditionally offered tax systems to attract highly qualified foreign workers and wealthy people to occupy and take over top management functions or realize investments in that jurisdiction. The government currently offers two such systems as described below:

    Eligible persons (category two) are subject to Income Tax only up to GBP 80,000 taxable income. The minimum taxable amount for affluent persons in a single year for which the tax is charged under this scheme is GBP 22,000 and a maximum of approximately GBP 30,000. Applicants must have an approved residential residence in Gibraltar for their exclusive use. At the same time, the government monitors whether the person has sufficient resources to provide nutrition for himself and his family; requiring evidence of personal property, although it is not necessary for a natural person to report wealth or income worldwide. At the same time, the government requires a natural person to have private health insurance related to that person and his family while staying in Gibraltar. Additionally, the applicant needs to stay in Gibraltar the previous five years.

    For the existing category three (since cancellation), a new category named “High Executive Possessing Specialist Skills (HEPSS)” (senior specialist) was introduced with an income exceeding GBP 120,000 per year and for new applicants with a qualification not in Gibraltar available and which, in the Government’s view, represents a special economic value for Gibraltar, as well as those who will hold a senior executive or top management position. In accordance with the HEPSS system, tax is payable only up to GBP 120,000 of taxable income based on gross income. Applicants for HEPSS must also fulfill the condition of residential accommodation and residence.

    Eligible Categories 3 and 4 were accessible to natural persons of foreign nationality from excluded or eligible companies and set a tax payable by these individuals of GBP 15,000, irrespective of their taxable income, but were canceled in 2007.

    Offshore business sectors

    In this section, we will deal with key sectors of the Gibraltar offshore economy.

    E-Commerce and E-Gaming

    With regard to e-commerce, the government elected in 2000 showed its intention very quickly, stating that: “The Government of Gibraltar believes that there are significant opportunities for enterprises operating in the e-commerce sector operating on the Rock. The Internet allows access to customers located in every corner of the world and we should be well prepared to operate international clientele.”

    The Electronic Commerce Ordinance was adopted by the House of Commons of the Gibraltar on March 5, 2001 and was considered an important step in the development of Gibraltar as an e-commerce node, which should be measured with closest competitors like Guernsey, Malta and the Isle of Man.

    This legislation has facilitated the use of electronic means for the transmission and storage of information and has recognized the legality of electronically concluded transactions. At the same time, it provided a framework for the recognition of electronic signatures and defined the activity and legal responsibility of service providers.

    In addition to an adequate legal basis, Gibraltar’s advantages in terms of geographic and structural position in the EU lie in the established base of professionally qualified forces, good telecoms and excellent port facilities. If the problems with Spain were finally resolved, Gibraltar could act as a tax-efficient gateway to electronic commerce in Spain and the rest of the EU for both physical and digital goods. Currently, Gibraltar favors digital products, including financial services with the strongest competition.

    By placing websites in Gibraltar to perform operations previously performed in high-taxation jurisdictions such as sales or marketing, financial management, financial services, and, in particular, the supply of digital goods such as music, video, training, software, etc., businesses can take advantage of the low taxation benefits of increasingly important parts of their operations.

    A specific example is the betting and gambling sector: In 2000 and 2001, Gibraltar attracted many bookmakers who fled high tax rates in the UK to set up offshore call center betting centers. However, in May 2004, Gibraltar demonstrated that its e-commerce capabilities are not limited to betting when the leading London-based independent Mac Futures has significantly expanded its presence in Gibraltar’s jurisdiction by opening a new business facility with hundreds of jobs in the presence of Prime Minister Peter Caruan.

    The gradually worsening tax climate in the United Kingdom and the ever more challenging international competitive environment drove many gamblers and gambling operators between 2006 and 2011 and many of them moved to Gibraltar.

    In December 2013, the UK government responded to the outflow of offshore gambling operators by imposing a 15% tax on the spot of consumption in order to prevent betting operators to enjoy the benefits of low-tax jurisdictions such as Gibraltar although they still addressed their offer to UK customers via online services.

    It is expected that this tax will cost online gambling industry GBP 300 million, but the question remains how these changes will affect offshore jurisdictions such as Gibraltar, which leaves a significant footprint in this industry. If the William Hill company’s answer is at least a hint, the future of Gibraltar as a sought-after offshore home after a UK betting provider remains secured. In an interview with reporters in December 2013, Andy Lee, managing director of William Hill, said the company was not planning to withdraw from Gibraltar. Currently, William Hill’s global division is based in Gibraltar, and employs more than 400 people. “Our staff are happy here, and there are reasons to remain here to stay competitive on this market,” Lee said.

    Banking

    The banking sector is well established in Gibraltar, both on the offshore and local markets, despite a steady decline in the number of banks in that jurisdiction, from 26 banks in Gibraltar in 1996 to 20 banks by 31 March 2013, of which ten are locally established banks, six branches and four electronic money institutions.

    Most banks based in Gibraltar are branches of major British, European and American banks. Banking activity focuses on asset management for wealthy people, because Gibraltar has been very much in favor of attracting these people through special tax regimes.

    Financial services in Gibraltar are regulated by the Commission’s Financial Services. In 2002, the Commission introduced significant changes in the way of supervising local bank and non-EEA bank branches by starting a risk-based approach whereby supervisory teams assess the institution from the point of view of the risks to which the institution is exposed due to its business or business activities. This new approach to supervision aims to concentrate supervisory resources on areas considered to be high risk for the institution to ensure that proper control mechanisms and risk reduction procedures are in place, or when corrective action is needed by the institution.

    The Banking Ordinance Banking Ordinance 1992 (as amended) abolished the earlier distinction between ‘A’ onshore and ‘B’ offshore licenses and a unified banking license was introduced. Therefore, licensed banks in Gibraltar can theoretically use “licensing” options and establish branches throughout the EU and the EEA without the need for further approval (except notification).

    The Gibraltar Deposit Guarantee Board has put into effect the deposit protection principle in line with EU directives in this area. The Deposit Guarantee Scheme was further extended with effect from 31 December 2010, so that an eligible applicant would be entitled to 100% of the total eligible deposits deposited with a defaulting bank (including all branches); or EUR 100 000 (or the corresponding amount in pounds) whichever is lower. Previously, this system covered 90% of the bank’s overall liability vis-à-vis the depositor, at a maximum amount paid to one person at GBP 18,000 (or EUR 20,000 if that amount was higher).

    Gibraltar is considered to be one of the most secure jurisdictions with regard to the risks associated with the legalization of proceeds from crime. Within the European Union, Gibraltar is required to transpose into its law all relevant EU directives, including directives on the fight against money laundering.

    Gibraltar was one of the first jurisdictions to introduce and implement legislation against the legalization of proceeds from crime, which covered all criminal activity.

    Like other European offshore jurisdictions, Gibraltar has also had to deal with the EU Savings Tax Directive and has decided to Withholding Tax on bank interest payments for EU nationals. In this way, Gibraltar has protected banking secrecy.

    Local jurisdictions faced fire from the Channel Islands because its legal status in relation to the United Kingdom and the European Union had the effect that this directive did not apply in the same way. However, on the basis of an agreement between the two governments, Gibraltar and the United Kingdom exchange information on savings income under the Directive, or only in the case of Gibraltar, if the savers decide, apply to residents in the United Kingdom who have an account Withholding Tax from the income from savings.

    The rate of tax was set at 15% between 1 April 2006 and 30 June 2008, then rose to 20% in the next three years and to 35% from July 2011.

    However, given that the EU Savings Tax Directive has been transposed into national law, the whole exchange of information has shifted significantly and the campaign against cross-border tax evasion has become a global issue. UK Offshore Territories face extraordinary pressure to make available information about bank account holders and end-owners of companies, with Gibraltar signing an Intergovernmental Agreement (IGA) with the United Kingdom in November 2013 to share information about its residents with bank accounts in their jurisdictions. The agreement is based on Model 1 of the IGA Agreement, which the US Treasury Department concluded with foreign governments in accordance with the US Foreign Account Tax Compliance Act (FATCA). At the time of writing, Gibraltar is considered to be close to FATCA IGA’s signature with the US.

    UK IGA’s signature collided with the OECD’s announcement that the United Kingdom issued a statement extending the territorial scope of the Convention on Mutual Administrative Assistance in Tax Matters of the OECD and the Council of Europe as well as to Gibraltar. Prime Minister of Gibraltar asked Britain’s Prime Minister David Cameron to extend the Convention to its jurisdiction. Inclusion in the Gibraltar Convention significantly extends the network of information exchange agreements.

    However, the Gibraltar Government has unequivocally expressed its full support for the efforts of the international community to improve tax transparency and fight against tax evasion.

    “The Gibraltar Government continues to hold the firm view that combating tax evasion and fraud is genuinely a global priority necessary to protect the integrity of public revenue, taxpayers’ confidence in the fairness and efficiency of their tax systems, and, last but not least, public confidence in global capital markets,” the government said in its statement in May 2013.

    The government, however, stressed the fundamental importance of maintaining a level playing field in international financial services, ensuring that all territories adopt the same frameworks and the need for strong enforcement measures in case of non-compliance.

    Investment funds management

    There is a busy investment management sector in Gibraltar with nineteen licensed portfolio management companies. Many banks in Gibraltar also offer investment management services, and there are also independent brokers.

    At the end of March 2012, the managed funds in Gibraltar amounted to GBP 8.1 billion, of which GBP 6.3 billion for banks and the remainder to investment firms.

    The financial services of the Commission are responsible for regulating the investment business in Gibraltar.

    Investment funds in Gibraltar are usually set up as unit trusts or open-end investment funds or, on the basis of the Companies Ordinance, as a private or public company. A public investment company (PIC) must have a minimum paid-in capital of GBP 50,000 and if it is not listed on a recognized exchange, it must have its registered office in Gibraltar.

    In July 2003, the United Kingdom agreed to grant licensing rights to allow local investment firms in Gibraltar to offer their services to entities in other EU Member States. Banking and insurance licenses were the third licensing “allocation” to the jurisdiction and the result was that companies regulated by a recognized competent authority, such as the FSA, did not need to seek approval from regulators in other Member States.

    However, this license did not allow companies in the Rock to offer services in the United Kingdom and was therefore the subject of a separate agreement between Gibraltar and Britain concluded in December 2005 which allowed Gibraltar-based investment firms to license (and market and sell) their products and services on the UK market.

    In 2005, Gibraltar established, by virtue of the Financial Services (Experienced Investor Funds) Regulations, 2005 funds of experienced investors. These are funds intended for professionals, movable or experienced investors. Investors in these funds must have a net asset value of over EUR 1 million or invest at least EUR 100,000. Normally, they can be set up within days and commence trading only need to inform the Financial Services Commission within 14 days of fund creation.

    This legislation also provides for license requirements for Non-UCITS retail funds and UCITS funds. Non-UCITS retail funds are licensed by the FSC and are subject to stricter regulation and limitations as to the types of investment activity they can develop. Prior to giving consent, the FSC must submit a number of documents, such as the fund’s prospectus, and the directors and managers of the fund are subject to stricter reviews than the EIF.

    UCITS funds are generally targeted at retail investors and allowed to license their services in the EU under EU Directives on undertakings for collective investment in transferable securities. However, UCITS funds must meet the requirements of the 1991 Financial Services Ordinance (Collective Investment Scheme) Regulations, which limits the amount that the funds can invest in a single issuer to 10%.

    At the end of 2011, 199 funds were registered in Gibraltar, registered with the EIF (including lower organizational units and sub-funds), with a total asset of GBP 1.35 billion. There were also 31 recognized funds established outside Gibraltar, including 19 UCITS-type funds and 12 funds recognized by foreign regimes.

    Gibraltar now has an advantageous position as an alternative to Dublin and Luxembourg for the establishment and management of hedge funds with the entry into force of the Alternative Investment Fund Managers (AiFMD) regulation in July 2013.

    AIFMD is a new regulation that applies to investment managers, notably EU administrators, but also to non-EU administrators who want to market their funds in the EU. It determines the way of realization of the marketing activity by these investment managers.

    According to the government of this jurisdiction, changes to fund legislation in that territory in 2012, in anticipation of the EU directive, have increased Gibraltar’s attractiveness as a home for large funds or funds wishing to relocate to Europe to meet new EU rules for the fund sector. As a result, Gibraltar is now specifically targeting New York and Latin American funds and fund managers in their promotional efforts.

    Albert Isola, Gibraltar Finance Minister, said: “This legislation provides Gibraltar with a great opportunity and a competitive edge that should bring about further growth in this key area of our financial services industry.”

    Trust management

    Foreign asset management has been a traditional business for Gibraltar for over fifty years. Originally, most of the trust business originated from wealthy UK entities and related to taxation, but in recent years they have gained importance in trusting property protection with a much more diverse clientele.

    The gradual tightening of UK law against leakage has limited the ability of UK citizens, but trust is still significant; a number of collective investment funds are naturally based on trusts.

    Gibraltar has a well-developed legislative and financial infrastructure for managing foreign assets and a large established trust base.

    Asset managers, if they are no longer members of legal and accounting professional organizations, must be licensed by the FSC, which applies a number of criteria in determining whether that natural or legal person is duly eligible to hold a license.

    The FSC Trust Division is responsible for overseeing sixty-eight groups (31 March 2013), all of which are subject to risk assessment.

    The basic legal regulations of trusts are contained in the Gibraltar Trustee Ordinance, which is a true copy of the British Trust Legislation. Gibraltar Trust Law also includes the Perpetuities and Accumulations Ordinance 1986, the Trustee Investments Ordinance, the Bankruptcy Ordinance, and the Trusts (Recognition) Ordinance, which transposed the Hague Convention into national law. The appeal is filed with the Privy Council.

    There is no provision to exclude inheritance rules abroad and non-recognition of foreign judgments.

    As in the United Kingdom, the essential requirements relating to trusts in Gibraltar are the oral or written foundations and the fact that the founder transfers the title to real estate (land) or personal property (other than immovable property) to the hands of one or more property managers to manage in accordance with the wishes of the founder in favor of one or more authorized persons.

    Trust documents are in the English language and there are no registration requirements, except for Trusts for Property Protection, which must be registered with the Registrar of Dispositions. Administrative Tax is not imposed. The usual trust duration in Gibraltar is 100 years. There are no restrictions on the accumulation of income for the duration of trust.

    Novelty:

    Current legislation of Corporate Taxes and related changes

    At the end of last year, an amendment to the Income Tax Act was adopted. This amendment changes the Income Tax Act in many places. In particular, it is a requirement for tax returns for companies and tax records, which includes the obligation for each Gibraltar company to have a tax identification number (TIN). The amendment came into force on 1 January 2016.

     

    We can help you with getting TIN number – contact us!

     

    Formerly, companies were only required to file tax returns and submit accounts only if they had taxable income within Gibraltar. The law now extends these requirements and stipulates that each company registered in Gibraltar must submit a tax return. This includes the submission of accounts even if the company has no income and the accounting is so-called sleeping.

    The submission of the accounting to the Tax Office must be done within nine months from the end of the accounting period!!!

    In addition, as part of the new policy, the presentation of the balance sheet and its economic good state are required.

    Gibraltar corporate income tax

    The tax is zero if the company does not trade within Gibraltar.

    Gibraltar’s Income Tax has not changed – Revenue from or in Gibraltar is taxed at 10% of corporate tax. However, returns from elsewhere do not fall under corporate tax and a zero or “sleeping” tax return can be filed.

    There are several benefits to tax returns. All companies now have a Tax Identification Number (TIN), which is especially useful when opening a bank account. Assigning a tax identification number is a signal to investors and business partners or authorities that the company is actually used for tax purposes.

    Gibraltar has become one of the most advantageous and best jurisdictions for company registration.

    BENEFITS

    • no tax on profits; activities outside Gibraltar are not taxed
    • a low tax rate of 10%; only the profits made in Gibraltar are taxed
    • Gibraltar does not have VAT; therefore, Gibraltar is not problematic from a tax point of view
    • goods imported into Gibraltar are subject to a duty of 0%, 6% or 12%
    • there is no Capital Gains Tax, Wealth Tax or Real Estate Tax

     

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Agreement on Processing of Personal Data CZ / EN