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Dutch Companies as a Tax Planning Tool

Dutch Companies as a Tax Planning Tool. St.Petersburg , September 28th 2010 Henk Eikelboom Jaap Bos. Why a company in the Netherlands ?. The Netherlands have a: - Good economic and financial climate - Political Stability High level of Infrastructure

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Dutch Companies as a Tax Planning Tool

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  1. Dutch Companies as a Tax Planning Tool St.Petersburg, September 28th 2010 Henk Eikelboom Jaap Bos

  2. Why a company in the Netherlands? The Netherlands have a: - Goodeconomic and financialclimate - PoliticalStability High level of Infrastructure Multilingualmajority of employees, up to date educated and wellinformed

  3. Key factors of The Netherlands Low joblessrate; low inflation and low interest rate; Good banking system - Wellorganized system formonitoring and controllingfinancialmarkets and compliancethroughlaws and regulations

  4. Fiscalkey factors (1) - Extensivetaxtreatynetworkwithforeigncountries (over 85!) Upfrontnegociationwith the taxauthorities is possible (rulings) -Advantageousrulesconcerningintrests, dividends and royalty’s

  5. Fiscalkeyfactors (2) Participationexamptionnotonlyfordividendsbutalsoforcurrencygainsancapitatalgainsonshares(>5% ownership) No taxesoncapital Carry back and carry over of losses

  6. Witholding Tax for income from Dutch BV to a Russian companies

  7. A Dutch B.V. (1) BV = private companywithlimitedliability Set up by a Notary (make up of the articles) Official permission of Ministery of Justice Minimum sharecapital is 18.000 euro

  8. A Dutch B.V. (2) Registered in the Chamber of Commerce Located in The Netherlands for optimal tax advantages Director can be another company

  9. Organigram Russiancompany dividends Oneor more BO’s Cyprus Ltd. interests loans Dutch B.V. In any country Subsidiaries

  10. Example loan Loan from Russian Comp. to subsidiaries Russian company Russian company I N T R E S T Witholding tax: 0% I N T R E S T Dutch B.V. Witholding tax: 35% I N T R E S T Witholding tax: 0% Subsidiaries Subsidiaries

  11. Example dividend Dividend from subsidiaries in Argentina to Russian holding Russian company Russian company Witholding tax: 0% Cyprus Ltd Witholding tax: 15% Witholding tax: 0% Dutch B.V. Subsidiaries (EU country without treaty) Witholding tax: 0% Subsidiaries (EU country)

  12. General remarks We don’t sell structures, we advise you what is the best in your situation. There are more possibilities by using f.e. Cyprus as a tax haven in combination with a Dutch B.V. Think twice; tax playing is not a game.

  13. What is Fundatio B.V.? A small trust office in Netherlands with licence of the Dutch National Bank. Member of a group of companies with tax advise, accounting and tax lawyers. An international player with a network in Europe, East Africa and Curacao.

  14. Howcan we serve you? We offer management and registered office for fix prices; We can advise you about international tax issues from The Netherlands; We take care of your business in The Netherlands; one stop shopping issue

  15. Fundatio B.V. Professional for professionals Rondweg 11d P.O Box 59 8090 AA WEZEP The Netherlands +31387370102 www.fundatio.nl henk.eikelboom@fundatio.nl jaap.bos@fundatio .nl

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