Quantcast
Channel: STREBER Weekly
Viewing all 106 articles
Browse latest View live

Flags of Convenience

$
0
0

Ahoy, skipper!

Unless you are looking for brief, general information about which tax haven to register your freight ship or yacht in and how flags of convenience work, this probably isn’t going to be an interesting article to you.

What is a Flag of Convenience?

A flag of convenience (FOC) is to a ship what a tax haven often is to a corporation: a cozy place to call home, far far from where it actually is located. The term FOC is sometimes considered pejorative and the term open registry or open ship registry is instead used.

Jurisdiction over maritime vessels is a complicated matter that dates back hundreds of years. It is to this day one of the least transparent industries and freight ships and yachts account for billions of value in pure assets as well as goods shipped across the globe.

The concept of FOCs has been around for a long time, but it started its modern history in the 1920s when American ship owners grew weary of increased regulations and started registering their ships in Panama.

Advantages of FOCs

A ship registered under a FOC is subject to far more lenient regulations than common flags when it comes to things like taxation, ownership disclosure, and workers’ rights. This can lead to access to cheaper labour and less money spent on insurances and liabilities.

Flying a FOC can save a lot of money for a shipping company and enable transport of goods otherwise not possible.

It can also be associated with significant tax savings. By claiming that a ship is domiciled in a tax haven, it can sometimes bypass certain import and export duties or other taxation. Things like tax residence work a lot differently at sea.

Ships owned through FOCs often have almost impenetrably secretive ownership.

 

Disadvantages of FOCs

To the shrewd ship owner, there aren’t a lot of disadvantages to flying a FOC aside from reputational disadvantages, which in and of themselves can be a problem.

The disadvantages are mostly to the seafarers, for whom fewer securities are guaranteed by law when working on board a ship that’s registered in a FOC jurisdiction.

Workers’ protection laws and regulations are rarely enforced in open registries. Screening of workers is also more relaxed, which can affect shipowners as well as workers in that less qualified staff can be certified.

Criticism of FOCs

The International Transport Workers’ Federation is a global union with over 4.5 million members. It has a division just for maritime called ITF Seafarers.

The ITF Seafarers campaigns against FOCs because they see them as hurtful to the industry and safety of workers.

Another organisation, the Paris Memorandum of Understanding (Paris MoU) has criticized open registries, for example going so far as to blacklisting Panama. This blacklisting was removed after Panama took steps to improve conditions.

Jurisdictions

The ITF has identified 34 open registered or Flags of Convenience. In brackets, number of ships registered followed by how many of those ships are foreign-owned. These numbers only refer to larger vessels and should be seen as indicative only, since they rely on aged sources (via CIA Factbook) and fail to take into account the full scope of open registries. The real numbers are higher.

Antigua and Barbuda 1,257 1,215 97%
Bahamas 1,160 1,063 92%
Barbados 109 83 76%
Belize 247 152 62%
Bermuda 139 105 76%
Bolivia 18 5 28%
Burma 544 352 65%
Cambodia 116 102 88%
Cayman Islands 149 73 49%
Comoros 120 101 84%
Cyprus 838 622 74%
Equatorial Guinea 5 1 20%
Faroe Islands (FAS) 37 28 76%
France (French International Ship Register) 162 151 93%
Germany (German International Ship Register) 142 95 67%
Georgia 427 6 1%
Gibraltar 267 254 95%
Honduras 88 47 53%
Jamaica 14 14 100%
Lebanon 29 2 7%
Liberia 2,771 2,581 93%
Malta 1,650 1,437 87%
Marshall Islands 1,593 1,468 92%
Mauritius 4 0%
Moldova 121 63 52%
Mongolia 57 44 77%
Netherlands Antilles 29 2 7%
North Korea 158 13 8%
Panama 6,413 5,162 80%
São Tomé and Príncipe 3 2 67%
Saint Vincent and the Grenadines 412 325 79%
Sri Lanka 21 8 38%
Tonga 7 2 29%
Vanuatu 77 72 94%

Jurisdiction Spotlight: The Gambia

$
0
0

The most recent member to the international financial centers, The Gambia threw its hat in the mix only a few years ago by enacting a couple of new laws and setting up a superficially very impressive regulatory environment with strong technology focus.

A lot of effort was spent on copy-pasting the legal framework of Mauritius while also borrowing from the UK and a few others.

But how has it gone?

And what about banking?

While The Gambia has a rich and interesting history that anyone curious about African history and slavery would do well to read into, it is not relevant to its current situation as a tax haven and, because I’m short on time, I will skip.

Very briefly, it was under numerous indigenous rulers until the British arrived in the 1600s. While the British and French fought over The Gambia, it retained British rule for the most part.

It gained independence from the British in 1965. It quickly fell into chaos and disarray, fighting a war with Senegal. Since the early 2000s, it has enjoyed political stability and socioeconomic development. It has a growing tourism sector to supplement its fishing and agricultural sectors (mostly peanuts).

Owing to early Arabic influences, the country is an Islamic republic. Its official language is English, which has served as a great advantage in ever since the political climate stabilized.

Geography and Demography

Gambia map offshore GBC

Map from Wikipedia.

Full Name: Islamic Republic of The Gambia (often just Gambia)
Official language(s): English
Other major languages: Fula, Jola, Medinka, Serer, Wolof
Type of government: Presidential republic
Legal system: English common law and customary law
Area: 10,689 km²
Timezone: UTC
Population: 1.9 million
GDP per capita: 2,000 USD
Currency: Gambian Dalasi (GMD)

Incorporation and Business

Generally

The Gambia launched its offshore sector in 2013, becoming the youngest offshore jurisdiction. While many of its efforts are admirable and its corporate solutions are delightfully diverse, the initiative generally seen as untimely and unfitting.

The jurisdiction went to great lengths to come up with an electronic apostille system, which in theory is years ahead of its time but in reality simply falls flat on that The Gambia offers no real advantage over other jurisdictions and as such has seen very little use.

A mere few thousand entities have been formed thus far, mostly the GBC 2 type. Formation costs are fairly low, often well under 2,000 USD for incorporation and 1,000 USD for renewal.

Reputation

Unknown. Neither good nor bad.

Regulator

While the iCommerce Registry acts as the nexus point for the Gambian offshore sector, regulatory responsibilities fall on a number of different authorities, all of which are gruesomely underfunded, understaffed, and suffering from rampant corruption. Transparency International ranks The Gambia has the 123 out of 167 in terms of transparency.

The iCommerce Registry often blurs the line between registry and agent, offering a number of services directly to end-users.

GBC 1

Essentially, an exact replica of the Mauritius’ law. GBC 1s are supposed to be resident or semi-resident companies paying a miniscule, symbolic tax in order to make use of tax treaties. One of the key differences is that The Gambia has signed an entirety of five DTAs, compared to the 56 Mauritius has signed.

A GBC 1 pays no tax on income earned outside of The Gambia, which is where most Gambian offshore companies are formed anyway, thus reducing the usefulness of a Gambian GBC 1 from small to none.

  • Minimum one director (can be corporate, but not if the only one).
  • Minimum one shareholder (can be corporate, but not if the only one).
  • Minimum one resident, natural-person member.
  • Registerd office in The Gambia.

Public Record

None.

Tax

1.5% of turnover or 32% on profits.

GBC 2

Again, by and large a carbon copy of the Mauritius’ law, which in turn is largely based on the BVI model IBC but with a number of tweaks. They even go so far as to call them IBC and offshore companies on their website.

  • Minimum one director (can be corporate).
  • Minimum one shareholder (can be corporate).
  • Registered office in The Gambia.
  • Must be operated from the Enterprise Zone or outside of The Gambia.

Public Record

None.

Taxation

None.

LLP

This one is actually potentially interesting. It’s borrowing heavily from the UK LLP legislation, which in and of itself is very attractive.

  • Minimum two members (at least two need to be designated members, comparable to managers or officers or directors).
  • Registered address in The Gambia.
    • List of designated members.

Public Record

None.

Taxation

None. LLPs are pass-through entities.

PLC

OK, fine. There is a PLC as well; a Public Limited Company.

That’s right, your dreams of being listed on the Gambian stock exchange has finally come true.

  • Minimum two directors (can be corporate).
  • Minimum two shareholders (can be corporate).
  • Minimum authorised share capital of 50,000 USD.
  • Company secretary required.

Public Record

Yes.

Taxation

A semi-territorial taxation system is used.

Record Keeping

Requirements exist but are not being enforced.

Licenses

Desperate for any sort of income, The Gambia has enacted a couple of licenses that they may issue:

  • Banking license
  • Brokerage
  • Education
  • Financial services
  • Funds
  • Gaming license (gambling)
  • Insurance

So far, I have heard of no one actually applying or obtaining any of these licenses. Those seeking such licenses are instead drawn to far more established jurisdictions.

Trust

Yep, a trust law exists. It has however not been tested yet and the cautious settlors and trustees of the world are keeping an eye on The Gambia, while continuing to use far more established jurisdictions.

Foundations

They threw a foundations framework into the mix as well, hoping to compete with all jurisdictions out there.

Practically zero usage so far.

Banking

It’s currently very difficult to open bank accounts in The Gambia or even for Gambian entities.

There are nonetheless several pretty good banks in The Gambia. Its banking sector has a bright future, if the regulators are able to cope with the increased demand relative to the increase of illicit funds and money laundering. While by no means as bad as Djibouti, Ghana, or Ivory Coast just yet, The Gambia is at major risk of becoming a money laundering nest.

FATF and its underling GIABA have been lenient on The Gambia so far, despite failing to reach the FATF’s recommendations, in no small part because of the jurisdiction’s relatively small size but also because the young republic is still very much a developing nation.

While major deficiencies have been discovered, they are not seen as egregious because there is relatively little money being passed around.

Open a Bank Account in The Gambia

Generally difficult remotely but personal accounts can be opened without too much trouble in person. The bank might ask for some vague justification as to why you are opening a bank account and it’s usually enough to say you plan to invest in the local or regional economy.

Corporate accounts are a lot more difficult, especially for the local offshore companies. Most GBC 2s in The Gambia bank in Mauritius or outside of Africa.

Banking Secrecy

Effectively, because The Gambia’s laws are outdated and the new-found secrecy laws are a lot more recent than the old banking confidentiality laws, the banking secrecy here is rigorous. It’s practically impossible for a foreign agency to get anything out of a Gambian bank.

Unless they approach the bank in another jurisdiction and attempt to pressure them there.

The Gambia has not signed up for CRS/AEOI and, in fact, hasn’t signed a single EOI treaty as of yet.

Banks in The Gambia

There are banks but hardly any will engage with offshore companies.

Unless, of course, you’re here to launder money.

 

Living in The Gambia

While one of Africa’s most developed nations, the harsh reality is that competition isn’t exactly fierce. Those seeking to settle down in the African mainland are likely to enjoy South Africa, Equatorial Guinea, Namibia, or Botswana more, but The Gambia can be very attractive.

It’s generally stable and its economic situation continues to improve.

Costs of living are low, the weather is generally fine, and English is perfectly fine to get you by and live comfortably in The Gambia, although you will forever be a foreigner.

Citizenship

Not particularly attractive.

Dual citizenship is only allowed for Gambian citizens who obtain another citizenship through marriage.

Taxation

Average to above average.

Final words

Worth keeping an eye on, but that’s about it at this point.

Don’t be the guinea pig, unless you really want to.

See also

What’s up in Myanmar?

$
0
0

When I scheduled this post, many months if not a year ago, Myanmar was not at all in the news the way it has been in recent times following the election. I aim to keep this blog apolitical, and I will not be going in-depth. Those expecting a treatise on the current political situation and future for Myanmar are going to be disappointing.

The Myanmar I first set foot in many years ago is very different from the Myanmar of today. It is not exactly a tax haven, nor is it a place most people would be comfortable opening bank accounts and storing large sums of money. Although it has many of the necessary attributes for precisely that.

Often touted as the next Asian economic giant, investors and advisers alike talk promisingly about Myanmar.

About Myanmar

Myanmar flagMyanmar is a country which shares border with Bangladesh, India, China, Laos, and Thailand. Until 1948, it was a British territory under the name British Burma.

Before becoming British, Myanmar was a regional powerhouse under various monarchies, tracing its history back to ancient times. The first humans arrived in Myanmar around 11,000 BC. Modern-type civilizations were formed around 1500 BC, with statehood popping up about 1,000 years later.

I know it’s a bit of a cop out, but while the history of Myanmar is very interesting, it isn’t actually very relevant for this particular context.

Since independence from the British, the nation has undergone wars and a military dictatorship that lasted almost 50 years, during which the country was very closed off from the outside world. In 1991, democratic elections were allowed although these were generally not considered fair and open elections.

Human rights have been routinely disregarded in Myanmar. The government has killed hundreds of thousands in skirmishes and when clamping down insurgencies, the most notable perhaps being the Rohingya.

In 2008, the military junta enacted a new constitution which would lead Myanmar on the path towards democracy or at least a variant of democracy that they saw fit.

The results of elections held in 2010 tipped the ice berg after rigging accusations and a fed-up and empowered population rose up, toppling the military junta by 2011. The results of the election were generally seen as favourable internationally, with diplomatic relations warming up after years or decades of silence or caution.

The first free elections in Myanmar were held in November 2015 and a new parliament convened in February 2016. Foreign relations have improved dramatically and foreign investment has started to pour in like never before.

Population is somewhere north of 51 million, most of which live in rural areas.

The economy is almost entirely dependent on petroleum gases and agriculture. The country has been subject to numerous sanctions, which has crippled its economic growth.

It is one of the poorest nations in Asia, suffering from decades of neglect and corruption. Infrastructure is largely bad if not almost entirely lacking. When I say that most of the 51 million inhabitants live in rural areas, I don’t mean quaint little villages just off the highway. These are villages where you would almost believe time has stood still.

Attempts at stimulating the economy through tourism were for long unsuccessful. However, this is one area that is improving. With much of the population being able to converse almost fluently in English, it is in many ways a more welcoming country than some of its regional neighbours. Since 2012, the visa requirements have been easing up for both tourists and business travellers.

The largest cities are Yangon (also known as Rangoon) with 5.2 million inhabitants, Mandalay with 1.2 million, and the cpital city of Naypyidaw with 1.1 million.

The currency is called Burmese kyat. It is one of the least valuable currencies in the world.

While the top-level domain .bu was created, it was never put into use. Instead, .mm is used.

Myanmar map

Banking Sector

Banks popped up shortly after independence and a central bank was enacted in 1952. With the military junta, all banks were nationalised and the government actively broke down the young banking sector.

The military junta made most of the old bank notes invalid, causing a deeply rooted lack of trust in government and in banking among the population.

The infamous Asia Wealth Bank (AWB) was formed in 1994 and was the first bank to issue credit cards. The bank initially received a warm welcome internationally but after it became clear the bank had no idea how or just no intention to follow international standards of compliance (such as they were back then), the bank was eventually shut down after it was declared a primary money laundering concern.

This all came about during the 2003 banking crisis in Myanmar, which was triggered by distrust and several smaller banks and unauthorized banks or semi-banks folding after their Ponzi-scheme-like, unsustainable lending strategies started to crumble.

This also caused a bank run at AWB.

By the end of the crisis, Mayflower Bank and Myanmar Universal Bank had also folded. Mayflower was also designated a primary money laundering concern, while Myanmar Universal Bank was nationalized.

Today, Myanmar is one of the least banked countries in the world, with some 95% of the population not using banks.

Tight government regulations are in place to control the flow of capital and issuance credit and interest rates, which on the one hand may be further holding back growth of financial services in Myanmar while on the other helps keep the fragile economy in check.

Today, the Myanmar banking sector is working hard to make amend for previous lapses in judgment and compliance. Eager to get into the enormous potential of Myanmar, banks are eager to let go off the past and give the banks a new chance.

While right in this moment banking in Myanmar is fairly lackluster, it will likely be one of the best of any developing country in a few years. Trying to get an unbanked population to bank has historically proven best by making banking simple, which includes taking a reasonable approach to compliance while embracing modern technology.

Banking in Myanmar

Opening a bank account is doable for non-residents. Remote account opening isn’t the norm but it does happen.

Personal and corporate accounts are accepted. Keeping a few thousand EUR/USD equivalent in the local currency will satisfy most banks, as long as your profile is overall not too suspicious.

Now, before you drop 1,000 USD on a Seychelles IBC and 2,000 USD on flight tickets to Yangon,

Interest rates of up to 10% (or even higher) for savings in the local currency can be opened with relative ease in person.

While foreign currency (including various Asian currencies) accounts can be opened with relative ease, transfer times can currently be very long. It is likely that every intermediary on the way performs a manual review of transactions to and from Myanmar, due to the jurisdiction’s spotty past.

Some banks are connected directly to money remittance companies such as Western Union and MoneyGram.

The leading banks are Kanbawza Bank, AGD Bank, AYA Bank, and Myanma Apex Bank.

Secrecy

Effectively very strict and probably completely impenetrable right now. This is not by choice but rather by omission and a side-effect of prolonged isolation.

While a degree of secrecy is likely to remain intact to foster trust in banking amongst the population, it is unclear how long Myanmar can afford to stay away from CRS/AEOI and – especially – FATCA. Not a single exchange of information treaty is in place.

Business

This isn’t an investment blog or even an investment article. Suffice it to say, though, that I the number of clients looking to enter Myanmar has never been higher and more companies are being formed in Myanmar than in the last 50 years combined.

This isn’t a jurisdiction like Hong Kong where you form a non-resident company and call it a day. Companies formed in Myanmar engage in business in Myanmar.

And they are subject to some pretty tough rules on what is and what is not allowed to import and export. Coupled with restrictions on currency exchanges, this can be  tough jurisdiction to break into even for the most seasoned business owner.

A number of special economic zones (SEZ) and foreign investment incentives exist to attract new business.

The MFIL (Myanmar Foreign Investment Law) sets out a number of advantageous and familiar regulations foreign investors can avail themselves of to set up shop in Myanmar. These include five-year tax exemption (can be extended indefinitely by approval) and other tax incentives. It is quite easy to obtain zero or very low effective corporate tax in Myanmar. The normal rate is 25%.

Incorporation fee is 1 million MMK (circa 750 EUR or 850 USD). Minimum two members are required. The minimum share capital required is 50,000 for a service company and 150,000 USD for a manufacturing company.

Record keeping requirements are strict but not onerous.

Since March 2016, Myanmar has a stock exchange; the Yangon Stock Exchange. Activity has been modest thus far with a whooping two listed companies so far: First Myanmar Investment and Myanmar Thilawa SEZ Holdings Public Ltd.

Costs of labour are low but rising.

With improved infrastructure, Myanmar is likely to continue becoming even more competitive to Indonesia and Vietnam for manufacturing jobs.

Living in Myanmar

As many back packers and an increasing number of business travelers can attest to, Myanmar can be extremely charming and inviting.

Obtaining permanent residence is no easy task at the moment. Efforts are being made to ease up on this, but the republic relatively young, if you remove the 50 or so years during which it did not see many foreigners.

While I enjoy every visit to Myanmar, it is not yet a country I would see many foreigners settle down in for any long period of time.

It is however a jurisdiction with tremendous potential for the near future, in almost every regard.

Further Reading

 

Jurisdiction Spotlight: Luxembourg

$
0
0

LuxembourgWe’re back in Europe, today taking a look at one of the least tax-haven-like tax havens: Luxembourg.

Or, if you ask a local: Luxembourg (French), Luxemburg (in German), or Lëtzebuerg (Luxembourgish).

Somewhere between Belgium, France, and Germany is this tiny nation of many languages, businesses, EU institutions, international organizations, and the lowest VAT (sales tax) in the EU.

Geography and Demography

Luxembourg map Europe

Map from Wikipedia.

Full Name: Groussherzogtum Lëtzebuerg, Großherzogtum Luxemburg, Grand-Duché de Luxembourg
Official language(s): Luxembourgish, German, French
Other major languages: None
Type of government: Unitary parliamentary constitutional monarchy
Legal system: Civil law
Area: 2,586 km²
Timezone: CET
Population: 560,000 million
GDP per capita: 100,000 USD
Currency: Euro (EUR)

Incorporation and Business

Generally

It is costly to form a company in Luxembourg and often takes quite a long time.

Luxembourgish companies are subject to a fairly high tax-rate on their worldwide income and diligent accounting records need to be kept.

So what exactly is the allure with forming a business in Luxembourg?

It used to be the low VAT, but due to changes in EU law for cross-border transactions whereby VAT is charged based on the consumer’s jurisdiction of residence as opposed to where the business is located, this is no longer so much the case.

Another big factor is that the corporate tax in Luxemboug – similar to Switzerland – is not necessarily written in stone. It’s negotiable, if you have tremendous amounts of money to negotiate with. The authorities in Luxembourg have decided it’s better to earn 1 million EUR in tax than 0 million EUR.

Companies that manage to negotiate favourable tax rates can then avail themselves of Luxembourg’s rich network of double taxation treaties to reach an overall low tax burden.

Another major drawing point of Luxembourg is it’s holding companies regime, which I will get to later.

Reputation

Generally very good. Some particularly grumpy compliance officers might find the jurisdiction’s reputation as a former banking-secrecy haven to be problematic, but that’s rare.

Regulator

No specific regulator. Companies are subject to the local courts. Financial services operators are generally answerable to the CSSF.

Business Types

Being a well-developed incorporation jurisdiction, Luxembourg has almost all business types one could ask for. The only type missing would be an LLC entity of the American variety.

In addition to sole proprietorships, Luxembourg offers:

  • SARL (société à responsabilité limitée): comparable to the German-law GmbH, which was the inspiration to the American LLC. Single-member SARLs are permitted. This is the most popular type in Luxembourg. Taxable entity.
  • SECS (société en commandite simple): similar to Limited Partnerships, in that it has at least two partners of which one has limited liability and the other does not. Tax transparent (pass-through).
  • SA (société anonyme): comparable to private limited companies and corporations. Popular with larger corporations. Can issue bearer shares. Taxable entity.
  • SECA (société en commandite par actions): a hybrid between SECS and SA, a SECA is essentially a limited partnership with shares instead of a partnership agreement. Taxable entity.
  • SPF (sociétés de gestionde patrimoine familial): a special type of holding company for family wealth management. Essentially a subcategory of other company types.
  • Soparfi (Société de Participations Financières): a special type of holding company subject to normal corporate tax. Essentially a subcategory of other company types.

The Luxembourg government offers the following comparison with German, UK, and US company types.

Germany Gesellschaft mit beschränkter Haftung (GmbH) Kommanditgesellschaft auf Aktien (KGaA) Aktiengesellschaft (AG)
United States Limited Liability Company (LLC) Limited Liability Partnership (LLP) Corporation (Corp.), Incorporated (Inc.)
Great Britain Private Limited Company by shares (Ltd.) Limited Liability Partnership (LLP) Public Limited Company (PLC)

Taxation

There is no easy way to tackle Luxembourg corporate tax. But that doesn’t mean I won’t try. Just bear in mind that it’s a lot more complex.

Luxembourg is one of those jurisdictions you can go to, sit down with the government, and negotiate a tax rate. Doing this requires enormous capital and turnover, measuring in the hundreds of millions of EUR (at the very least).

Additionally, Luxembourg exercises a form of quasi-territorial taxation. Tax residence of a company in Luxembourg is determined by where its legal seat and where its central place of management is. Non-residents are only taxed on Luxembourg-sourced income.

This means that an entity formed in Luxembourg is, if not operated from Luxembourg, exempt from tax in Luxembourg.

This is by no means unique for Luxembourg, but I see a lot of confusion on this topic.

The tax rate for a resident company is often just under 30%, depending on local taxes.

Luxembourg Holding Company

The infamous 1929 law ceased to be in December 2010.

As mentioned earlier, two types of holding companies exist now.

The SPF is a passive investment vehicle that can only engage in acquisition, holding, and sale of financial assets. The shareholders of an SPF can only be family members and trustees. Corporate shareholders are not permitted for an SPF.

SPFs are exempt from corporate tax but are subject to a 0.25% subscription tax on the deposited share capital, minimum 100 EUR and maximum 125,000 EUR.

A Soparfi is a regular company which is taxed normally on commercial activities. However, on holding activities, it can be subject to an effectively low tax rate that’s especially suitable for international tax planning. That’s as in-depth as I will go here. If I take the plunge and start talking about the different dividends rules, this would quickly turn into a tax essay, which is not my intention.

Record Keeping

Required and enforced.

Public Records

Varies but ownership is generally protected.

Banking

Luxembourg has never quite held a candle to Switzerland, but it has one of the best banking sectors in the world when looking at things like quality, sophistication, and innovation. I cannot comment on the financial stability of banks, though.

Open a Bank Account in Luxembourg

It’s a mixed bag, but generally leaning towards being difficult and snobbish.

There are attempts being made to modernize and streamline the process. No longer able to rely on secrecy, banks in Luxembourg have taken to investment management (i.e. private banking, often with a minimum of 1 million EUR) but you can find banks such as ING and BIL which (from time to time and with varying degrees of success) accept non-residents quite openly. At least as long as they live in the EU/EEA or carefully selected countries.

Luxembourg desperately wants to position itself as a fintech hub. The current financial services climate is not terribly conducive to this, with an outmoded approach to risk of remote account openings.

Banking Secrecy

Formerly very strict but nowadays in-line with EU standards. You can’t really hide money here unless you are EU non-resident and even then, Luxembourg has signed up for CRS/AEOI.

Banks in Luxembourg

There are 98 banks licensed in Luxembourg. This doesn’t include the 11 branches of non-EU banks and 30 branches of EU banks. Additionally, there are 13 rural banks.

The CSSF maintains a list of all banks in Luxembourg.

Living in Luxembourg

It’s surprisingly beautiful and charming. Good connections to neighbouring countries and European hubs via plane and train.

Politically stable and with high standards of living, foreigners who come to Luxembourg often stay for a long time, especially if they learn Luxembourg (and French and/or German).

The infrastructure is among the best in the world. Healthcare and education are highly regarded.

Costs of living are high.

Citizenship

Citizenship is attractive but, lacking any provable connections to Luxembourg, takes seven years of residence and passing an exam in Luxembourgish.

Taxation

As a full-time resident in Luxembourg, taxes are quite high.

Luxembourg uses the concept of domicile and customary place of residence, which doesn’t necessarily count number of days spent in the country. The tax authorities in Luxembourg are generally lenient. A part-time resident in Luxembourg can easily qualify for very low if not zero tax.

Final words

Tremendously more costly than forming a company in for example Cyprus, Luxembourg offers similar tax benefits for non-resident companies.

Banking is of high quality in Luxembourg but opening an account can be a hassle and downright hostile. It’s getting better and that trend needs to continue for Luxembourg to remain an important banking jurisdiction long-term.

Vacation

$
0
0

Dear readers, commentators, forum posters, and community members in general,

I am taking a vacation for an undecided period of time. The degree of vacation is also undecided, in that I expect to not completely avoid this website and others like it.

What happened?

In November 2015, I moved the blog and forum from a shared server to a private server. I did this for a number of reasons, none of which really matter here.

In 2014 or so, I had a data-loss scare. Nothing was lost but in a moment of clarity, I set up rigorous back-up procedures with daily off-site back-ups.

Apparently, those procedures were not copied over to the server. Since November 2015, no back-ups were made.

On the 28th of May, I noticed that the website was not loading. I logged in to the server only to find that the file system was in a read-only state. After further study, I found that the file system had been corrupted.

Here is a bunch of technical details few of you will find interesting.

This site uses WordPress and MySQL as database, using InnoDB as storage engine. Lots of website use this exact structure and it’s fine. In fact, it’s rock solid. Provided you have a back-up procedure.

The corrupt file system prevented the site from loading and dumping the database was not working. After fixing the file system corruption, the sites loaded temporarily but soon came crashing down again.

I’m still sorting out what happened but so far, it seem as if the InnoDB files or index on the file system were lost when the file system was fixed.

While I still have all the files, piecing them together without an index is nearly impossible with InnoDB.

Technical details end.

The data isn’t lost and I might be able to restore data at some point in the future.

What happens now?

The website will be back. The forum will come back in a couple of days has already come back (starting from scratch) and when my indeterminate vacation is over, so will the posts.

I have a lot going on right now and it’s been affecting the quality of the posts, I feel. Many of them were rushed hours before being published, instead of being more thoroughly planned out and written ahead of schedule.

I will take this time to consider the future of STREBER Weekly. I have been generally happy with how the format has been lately but maybe this time off will give some perspective.

From a technical point of view, this new site (also using WordPress) is hosted on a different server with daily back-ups already in place. Next step is to set up a real-time slave of the database.

And if I cannot recover the data from the old database, I will simply have to re-write those lost articles. To me, that’s not such a terrible thing. Some of the earlier articles were poorly written; I’m a better blogger now than in 2014 and 2015.

I had any way almost reached the end of the Jurisdiction Spotlight series and was going to start re-writing articles, both for the sake of quality and also to have more up-to-date information.

What can readers do?

Some of you have already reached out and offered technical assistance. While this is very kind and thoughtful of you, I must decline any such offer.

In looking through the individual database files, I noticed that many of you were messaging with each other using the forum’s private messaging functionality. I simply cannot risk anyone seeing those messages. Even I don’t want to read them.

For now, all you can do to help is to check back in a few days when the forums should be up and running again. Forums are back online using bbPress, meaning one log-in will cover both blog comments and forum posts again.

Most of all, please know that I appreciate each and every one of you. Every comment and forum post, I feel, goes towards a more informed public about offshore banking, international financial services, and cross-border incorporation services and structures.

Take care and be well!

Streber

Vacation Update

$
0
0

After a few days of turmoil, I have an update to share.

Articles / Blog Posts

In terms of written content, I am happy to report a complete recovery except for Jurisdiction Spotlight: Luxembourg. Out of over 150 articles, I am quite content re-writing one article. Thanks to two members sending me cached copies of the article, Jurisdiction Spotlight: Luxembourg is now back!

Very sadly, comments made after November 2015 are missing.  There is no practical way of recovering those.

Images are missing, at least images that I didn’t get from Getty Images. Over the coming months, I will probably be going back sporadically and adding flags and maps for Jurisdiction articles.

Many thanks to @balboni, @Vadim, and @unstoppable for helping with the recovery!

Forum

Devastatingly, the forum posts are permanently lost. Restoring them would require near-forensics levels of data recovery. This is an absolute tragedy because it isn’t just my writing that is lost; its hours upon hours of research, input, and discussion by you that has been lost. There is unfortunately no way to get those posts back.

While it has been relatively easy to recover the at-risk-of-loss posts from Google cache, The Way Back Machine, and other sources by just copy-pasting text, this approach does not work with a forum. Even if public caches of forum posts were possible, it would take a colossal amount of time to recreate the forum (thread by thread, post by post, user by user).

The forum is wiped clean.

It took many months to build up the last forum and I expect that this dreadful loss of data will essentially put us back to square 1.

The only good news in this otherwise dark chapter of this whole saga is that the new forums are interconnected with the blog, meaning a single login for blog comments and forum posts. The two are now part of the same system. Fully backed-up, redundant system.

Vacation and Future

While I will be active on the website and elsewhere in responding to comments and forum threads, the blog will remain in vacation-mode.

I have decided to resume the blog when I have at least a certain number of posts lined up. The best times of this blog have been when I have had a few weeks’ buffer. The poorest-quality articles were those thrown together quickly a few hours before publishing.

This can mean the vacation will last for a few days or a few weeks. For one, my schedule can be very hard to predict. Furthermore, inspiration comes and goes.

 

— Streber

 

Viewing all 106 articles
Browse latest View live