Gibraltar-based RegisterAnAircraft.com (RANA) is the aviation division of The Sovereign Group. Combining the experience acquired over 20 years in the field of aircraft registration and offshore company management, RANA offers a complete range of professional and highly tailored services to aircraft owners and operators worldwide.
Sovereign is able provide introductions to a number of banks in the UK and elsewhere in the world with which we have long-term relationships. Sovereign can also assist with account opening formalities.
Insurance is one of the most effective ways to manage risks and protect your assets, and is a vital part of the wealth management process. Gibraltar-based Sovereign Insurance Services (SIS) provides a full range of insurance broking services – from home, contents, travel, accident and life cover through to more complex products such as “key man”, professional indemnity and kidnap and ransom cover – at the most competitive pricing levels available in the international insurance markets. SIS is licensed by the Gibraltar Financial Services Commission to act as an insurance intermediary for general insurance business within the European Economic Area (EEA) but also has strategic partnership arrangements with a series of underwriters and brokers throughout the international insurance community so as to be able to meet a client’s insurance requirements anywhere in the world.
Intellectual Property Planning and Royalty Routing
The intellectual property (IP) associated with a business name or system can be one of its most valuable assets – but only if it is properly protected. Any business that wishes to establish a national or international identity should take steps to protect the use of its name, logo or other IP, such as patent rights, formulae/processes, designs, trademarks, franchises, licence agreements, “know-how” and copyrights. Given the importance of IP to modern businesses, Sovereign has established an intellectual property division that specialises in registration, monitoring, advice and proactive assistance.
A UK limited company, used in conjunction with various offshore entities, is an ideal vehicle to create effective tax efficient structures for royalty routing and the holding of assets such as intellectual property rights.
International Tax Planning
It is relatively straightforward to set up or purchase a company but it is vital to get proper advice on how to structure the ownership of that company, how it should be administered and how to organise its commercial arrangements. Every case is different and a high level of expertise is required to ensure that the advice is up-to-date, effective and fully compliant. Once we have understood your personal and business requirements, Sovereign is in a unique position, through its global network of offices, to advise on a suitable structure which will meet those needs and should result in significant tax savings.
Marine, including Yacht Registration
Gibraltar-based RegisterAYacht.com (RAY) is the marine division of the Sovereign Group. It was formed in 2000 to provide marine corporate and administration services to yacht owners, as well as to maritime law firms, yacht managers and brokers and other professional firms involved in the yachting industry. Initially established to register vessels under the British Red Ensign, RAY is now registering, administering and managing yachts – both pleasure and commercial – on a worldwide basis.
Non-Domiciled status in the UK
Despite the recent introduction of an annual charge, substantial taxation benefits accrue to UK residents who are not UK domiciled, often referred to as “non-doms”. A person who is UK resident but not UK-domiciled can apply to be taxed on a remittance basis, paying income tax only on income and capital gains that arise within the UK or on foreign income and gains that are remitted to the UK.
A non-domiciled individual who has resided in the UK for the fewer than seven out of nine years simply has to make a claim to be taxed on the remittance basis on their UK self assessment tax form. However, if an adult non-UK domiciled person has resided in the UK for seven or more of the past nine years and they have overseas income or gains in excess of £2,000 per annum then they must pay the annual remittance basis charge of £30,000 to continue to apply this basis of taxation. This charge rises to £60,000 for those resident for 12 of the last 14 years, and to £90,000 for those who have lived in the UK for 17 of the last 20 years.
Excluded Property Trusts (EPTs) offer capital gains tax (CGT) and inheritance tax (IHT) planning opportunities for non-UK domiciled individuals – especially those who have lived in the UK for more than seven of the past nine years but who are not able or willing to pay the annual remittance basis charge starting at £30,000.
An EPT is typically a discretionary offshore trust and the assets settled must be non-UK situs. Effectively an EPT offers permanent shelter from IHT even if the settlor subsequently acquires a UK domicile or is deemed to be UK domiciled. Furthermore any gains made by assets in this form of trust – or made by any underlying offshore companies in the EPT – are not subject to UK CGT, even if the gains are UK-sourced, such as the sale of a UK property.
Non-UK domiciled status for UK expats
Liability to UK Inheritance Tax (IHT) is governed by domicile. Many UK expatriates fail to realise that, although they are no longer resident in the UK, they remain subject to UK IHT on their worldwide assets unless they have actively shed their UK domicile and established a new domicile outside the UK.
In order to lose UK domicile status, it is necessary for a person to have been domiciled abroad for a period of at least three UK tax years and to be able to demonstrate that they do not intend to return to the UK. To achieve this, they will need to cut all ties with the UK by, for example, selling property, closing bank accounts and cancelling club subscriptions. Other actions that reinforce the decision include drawing up a foreign will and demonstrating a wish to be buried in the new jurisdiction.
If you have not acquired an intention to remain permanently or indefinitely elsewhere then your domicile remains UK for IHT purposes. Sovereign has processed many successful applications for clients seeking certainty on non-UK domiciled status. A positive counsel opinion regarding a new domicile of choice should be definitive and enables the client to plan against UK IHT with confidence.
For IHT only, the UK also has a concept of “deemed domicile” which occurs when a non-UK domiciled individual has been tax resident in the UK for 17 out of the previously 20 tax years. Once deemed domicile has been acquired, it takes three years of non-residence to lose it.
If a person is UK resident but not UK domiciled, then they will be liable to IHT only on their UK situs assets, with a few exceptions such as non-sterling currency in a UK bank account. If a person is UK resident and is also “deemed” to be UK domiciled then they will be liable to UK IHT on their worldwide assets. This liability remains even during a three-year period of non-UK residence that is undertaken to lose a deemed UK domicile.
Overseas Property Ownership
Sovereign assists many of its clients with the acquisition of real estate worldwide. We advise on tax and structuring and can manage the transaction process and financing arrangements. With our regional knowledge of property ownership laws and regulations, along with our tax planning expertise, we can help you reduce any potential exposure. Most people who own or intend to own property abroad will not be fully conversant with local legal procedures or taxes – stamp duties, municipal and wealth taxes – and may not fully recognise the longer term implications in terms of potential exposures to capital gains tax, inheritance tax or forced heirship rules. Substantial benefits may be derived through the use of corporate, trust or foundation structures to address these issues.
There is a requirement for UK companies to have a minimum of one physical person of any nationality and residence to be appointed as director and Sovereign is able to provide directors if required.