From: Jim Hart <hart@chaos.bsu.edu>
Date: Wed, 24 Nov 93 21:13:23 PST
To: cypherpunks@toad.com
Subject: Tax Havens on the Net
Message-ID: <199311250609.AAA01325@chaos.bsu.edu>
MIME-Version: 1.0
Content-Type: text



---------------------
Tax Havens on the Net
---------------------
compiled by James R. Hart

sources:
Internet Connectivity List -- Larry Landweber, U.Wisc.
	ftp.cs.wisc.edu ../connectivity_table   Version 9, 
	August 1993
Hoyt L. Barber, _Tax Havens_, McGraw-Hill 1993

Codes used to  indicate sites in each country with access to 
the Global Multiprotocol Open Internet:

BITNET
b: minimal, one to five domestic BITNET sites
B: widespread, more than five domestic BITNET sites

IP INTERNET
I: = operational, accesible from entire IP Internet
i: = operational, not accesible via the NSFNET backbone

UUCP 
u: minimal, one to five domestic UUCP sites
U: widespread, more than five domestic UUCP sites

FIDONET
f: minimal, one to five domestic FIDONET sites
F: widespread, more than five domestic FIDONET sites

OSI
o: minimal, one to five domestic X.400 sites
O: widespread, more than five domestic X.400 sites          

------------------------
and without further ado:
------------------------

Aruba
net access: ---f-
languages: Papiamento, English, Dutch, Spanish
currency controls: none?
bank secrecy: moderate (numbered accounts not 
	permitted)
preferred legal entities: Aruba Exempt Company, 
	NV (Dutch legal tradition, bearer shares allowed)
taxes: no income tax on AEC or shareholders, no 
	witholding of any kind
tax treaties: none?

Austria
net access: BIOUFO
language: German
currency controls: ??
bank secrecy: good; numbered accounts available
preferred legal entities: limited liability company, stock 
	orporation
taxes: corporate tax.  no bank interest tax.  20% divident 
	ax.
tax treaties: many, OECD model, primarily personal and 
	orporate income
contact: Price Waterhouse, Austria

Barbados
net access: --u--
language: English
currency controls: some (none for offshore banks & 
	nsurance)
preferred legal entities: company, public company, 
	offshore bank, exempt  insurance 
	company, foreign sales corporation , 
	international business company
taxes: income tax offshore banks and international 
	business companies 2.5%, exempt insurance  
	companies and foreign sales corporations none
tax treaties: double-tax treaties with 5 major countries (incl. 
	U.K. & U.S.)

Bermuda
net access: --uf--
language:  English
currency controls: none for nonresidents
bank secrecy:  moderate
preferred legal entities:
                local (conduct business in Bermuda, must be 60% 
		Bermuda owned),
	exempt (only conducts business outside 	
		Bermuda)
		-- min. capitalization US$12,000	
		-- extensive background check on the 
		    principles
taxes: no income, profit, sales, value added, witholding, or 
	capital gains taxes
tax treaties:  no double-tax treaties.  U.S. can be provided
	 with tax information concerning civil & criminal 
	tax cases

Costa Rica
net access: bIuf-
language: Spanish
currency controls: only on local currency, applies only to 
	citizens or legal entities
bank secrecy: good
legal entities: 
	individual enterprise/limited liability
	collective company
	limited partnership	
	limited-liability company
	stock corporation (aka chartered company): most 
	common
taxes: 15% on dividents for some nonresident 
shareholders, moderate corporate
	income, payroll, imort, real estate taxes.  
Exporters exempt from most
	taxes.
tax treaties: no double-tax treaties.  Caribbean Basin 
Initiative exchange-of-information
	agreeement signed but not yet ratified (as of 1/93).

Hong Kong
net access: BI-F-
languages: Cantonese, English
currency controls: none
bank secrecy: moderate?
preferred legal entity: limited-liability corporation 
	(English common law Companies Ordinance) 
taxes: 16.5% domestic source corporate  income, 15% 
	domestic employment wages, 15%  on domestic 
	property rental income	
tax treaties: no double-tax agreements
n.b.: treaty to return Hong Kong to Communist China in 
	1997

Ireland	
net access: BIUFO
language: English
currency controls: none?
bank secrecy: moderate?
preferred legal entity: noresident company (private 
corporation w/limited liability,
	must conduct operations outside Ireland)
taxes: only on Irish operations
tax treaties: many double-tax treaties
n.b.: those with Irish grandparents can obtain second 
	citizenship

Leichtenstein
net access: ---f-
languages: German, Alemanni
currency controls: none
bank secrecy: excellent
preferred legal entities: allows any type found anywhere 
in the world (!)
	establishment (limited liability, unlimited duration)
	company limited by shares
	foundations and trusts 
taxes:  none for income outside Leichtenstein.  Net worth 
	tax of 0.01% on capital and reserves (min. 1,000 
	Swiss francs), local  resident taxes
tax treaties: not party directly or indirectly to any 
	exchange-of-information agreements
	double-tax treaty exists only with Austria
n.b.: bankers won't assist law enforcement officials with 
	drug, fraud, theft, or tax investigations.  They 
	might assist in money laundering and insider
	trading investigations, informing the customer 
	first.

Luxembourg
net access: bIUFO
languages: Letzeburgesh, French, German, English
bank secrecy: moderate
preferred legal entity: holding company
taxes: holding companies pays only 10% registration fee 
on issued shares and
	0.20% annual capital tax on issued capital bonds.
tax treaties: many double-tax treaties
n.b.: EC member

Malta
net access: --u--
languages: Maltese, English
currency controls: none
bank secrecy: good
preferred legal entities: offshore notrading, trading, 
banking (overseas, subsidiary, local), insurance, trusts
taxes: nontrading exempt, trading very low
tax treties: many double-tax treaties	
n.b.: EC member

Netherlands
net access: BIUFO
language: Dutch
currency controls: ??
bank secrecy: poor
preferred legal entities: private or public NV (can have 
	bearer shares)
taxes: complex, high (many loopholes for large offshore 
	companies)
tax treaties: many

Panama
net access: b-uFO
languages: Spanish, English
curency controls:  none
bank secrecy: good; numbered accounts permissable
preferred legal entity:  corporation
taxes: none on income generated outside Panama
tax treaties: only on shipping income

Singapore
net access: bIuF-
languages: Malay, Mandarin, Tamil, English
currency controls: none
bank secrecy: moderate; numbered accounts available
preferred legal entities: private limited company
taxes: none  on dividends, foreign deposit interest, or 
income derived from
	outside Singapore. 	
tax treaties: many	

Switzerland
net access: BIUFO
languages: French, German, Italian, Romansch
currency controls: none
bank secrecy: moderate to good; numbered accounts 
	available 
preferred legal entity: AG (stock company under Laws of 
	Obligation)
taxes: 3.6-9.8% worldwide income tax for operating 
companies, 35% 
	witholding tax on interest and dividends
tax treaties: many double-tax treaties

Vanuata
net access: --u--
languages: Melanesian, French, English
currency controls: none
bank secrecy: moderate?
preferred legal entities: holding, trading, agency, mgmt. 
service, contracting
taxes: no income or capital gains taxes
tax treaties: none

Western Samoa
net access: --u--
languages: Samoan, English
currency controls: none
bank secrecy: good
preferred legal entities: international company, offshore 
	bank, insurance company
taxes: none for companies under offshore acts
tax treaties: none

If you like having this information, let me know.  Also let 
me know  what other kinds of information you need on tax 
havens and net access; I'd love to be of service.  If you 
have corrections to or additional information for the Tax 
Havens on the Net list, I'd be  happy to add it with full  
attribution (or full privacy, as you prefer).   To preserve 
your privacy, feel free to use anonymous remailers and 
encryption.  My PGP key enclosed below.

James R. Hart			hart@chaos.bsu.edu

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