We design custom solutions around each client's circumstance, reviewing each individual scenario to optimise taxation and the tax treatment between one country and another.
We specialise in creating solutions to re-define a taxable event – contractual arrangements allowing for legal changes to the characteristics of assets to take advantage of double tax treaties between two jurisdictions.
© Nobuyuki Taguchi
Occupational pensions have long been recognised as an efficient personal financial planning tool. With an ever-evolving global business market, more and more governments are entering into tax treaties.
Some agreements allow people working in one country and contributing to a pension there to take benefits in another country but to only pay tax in the country were the pension originates.
Tax rates in Hong Kong are comparatively lower than in other jurisdictions. Certain types of income are 'zero-rated' for tax purposes, meaning potential tax benefits can be significant.
Our expertise lies in forecasting your future financial situation coupled with government trends in levying taxes.
For example, a foreigner investing into the United States, residing in a country without a tax treaty with the USA, should consider investing via a corporate structure. Failure to do so would result in paying both US taxes and possible additional taxes in their home jurisdiction.
The tax treaty allows for an exemption of taxes levied due to the receiving jurisdiction’s benefits it has under its double tax treaty with the other jurisdiction.
A legal opinion is sought in every case to confirm the full legality of the structure and the resulting taxation of the assets.
Typically Centurion obtains tax opinions from Baker & McKenzie, DLP Piper, Lord Locke and Ernst & Young.
For expatriates, we recommend alternatives like tax deferral, a secondment, or a pension arrangement to reduce taxation.
Tax structures designed by Centurion include