Home | Offshore Companies | Offshore Banking | Offshore Trusts | Introducers | | Search

offshore companies and banking graphic


	Download Centre Jurisdiction Centre Brochures View GTA Trailer View GTA Adverts Audio Introduction Group Addresses Compare Jurisdictions Case Studies Daily Tax News Monthly Newsletter Weekly China News Ordering our Services Fee Schedule Currency Converter Quotations Ready-Made Companies Tax Treaties Jurisdiction Laws



Company Case Studies



Intermediate Finance Company

An Israeli investor is investing in the Czech Republic. A substantial part of the investment will be financed with debt. As the Czech withholding tax on interest paid to Israel is 10%, he wonders whether this withholding tax can be avoided by structuring the loan through a third country. Suggested solution: Interest paid by a debtor in the Czech Republic to Israel is subject to a 10% interest withholding tax (as reduced by the tax treaty between the two countries). Interest received in Israel is subject to 36% income tax. A back-to-back loan via a Luxembourg intermediate company could be a tax-effective solution. The tax treaty between the Czech Republic and Luxembourg provides for a 0% withholding tax rate. In Luxembourg, a ruling can be obtained from the tax authorities, thus minimising exposure to Luxembourg tax. According to Luxembourg domestic law, there is no withholding tax on interest paid abroad. Therefore, the interest can be paid to any country (including offshore financial centres) without attracting any further tax.

Print Page | Email Page



		QUICK ANSWERS



		PRICES AND FEES



		QUOTATIONS



		NEED ADVICE?


	Jurisdiction Info »


	GTA Newsletter For the latest tax management news subscribe here.



		OFFICE LOCATOR



		MAKE CONTACT



		CALL BACK



		HOW TO PROCEED



		STOCK LIST



		ORDER NOW



	Terms & Conditions \| Legal Warnings \| Licensing \| Privacy Policy © GTA Worldwide 2008 - 2009