Dividend Structure

This structure is appropriate for most entrepreneurs with annual pre-tax profits in excess of € 30.000. Useful for subsidiaries in most EU-countries as well regardless of the entrepreneur’s residency. For tax reasons the management and control of the Cypriot holding company has to rest with local directors provided by Freemont Group. The structure has five successive layers that are related as parent-subsidiary companies:

• Offshore Foundation: not subject to tax (unless it has income derived from sources in Panama). Offers asset protection and anonymity. Holds shares in:

• Offshore Investment Holding Company: not subject to tax. Can build protected capital reserves in Luxembourg, Switzerland or Austria with dividends received from its subsidiary:

• Cyprus Holding Company: not subject to taxes on dividends in Cyprus and avoiding withholding taxes on dividends; crucial intermediary for transferring dividends from high-tax countries, via a low tax EU-member, to a zero-tax offshore jurisdiction. Holds shares in:

• Holding Company: avoiding taxation on profits from the sale of shares in its subsidiary:

• Operating Company: running the new or existing business operation. Paying the Corporation Tax in its country of residence, unless Import/Export Structure or Royalty Structure apply. The Corporation Tax is the only tax that needs to be paid with this structure.

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