What is re-invoicing?
Re-invoicing is the use of a tax haven corporation to act as an
intermediary between an onshore business and his customers outside
his home country. The profits of this intermediary corporation and
the onshore business allow the accumulation of some or all profits
on transactions to be accrued to the offshore corporation. It should
be noticed that a similar structure can be utilized by an importer.
What would be an example of re-invoicing?
An onshore corporation sells $1,000,000 of goods or services to
France normally every year. Assuming cost of goods and services
sold and operating expenses are $600,000. the onshore corporation
earns $400,000 on its sales before taxes. Taxes will average say
$160,000 thus reducing net profits to $240,000.
The onshore corporation establishes a tax haven corporation to
act as intermediary managed by a company set up and managed by our
Sovereign Management Services S.A. The onshore corporation sells
its goods and services to the tax haven corporation on paper for
say $600,000. The tax haven corporation in turn sells the goods
and services to the French client for $1,000.000. The tax haven
corporation, thus earns $400,000. Since there are no taxes, $400,000
is the net income after taxes. The exporting corporation shows no
profit. ($600,000 gross sales less $600,000 cost of goods sold).
The $400,000 in tax-free income is then deposited in a bank account
or other investment instrument according to the wishes of the onshore
corporation. The account is under the control of the onshore corporation.
The basic process of re-invoicing saved the onshore corporation
$160,000 in taxes less a small re-invoicing charge.
Why are the tax haven corporation's profits free of taxes?
The intermediary corporation is formed in a country that has no
taxes on import-export transaction. For example, the British Virgin
Islands, Nevis, and Panama have no income taxes on re-invoicing
transactions.
How Is the offshore company structured?
To provide anonymity, the nominee officers and directors are provided
by Sovereign Management Services S.A. who manage the company. Bearer
shares can be issued and delivered to the owner as proof of ownership
or even better the company can have its shares owned by a Foundation,
in which case registered shares will be issued to the Foundation,
and a beneficiary agreement can be set up for the owner.
How does Sovereign Management Services S.A. know what to re-invoice?
The beneficial owner of the intermediary company provides instructions
on a regular basis by facsimile, e-mail or courier.
What About confidentiality?
It is the policy of Sovereign Management Services S.A. as well as
the laws of Panama that information is not released without consent.
To do otherwise violates secrecy laws and in Panama it is a jailable
offence.
What Happens To the Offshore Tax Free Profits that Are Earned?
They can be immediately released as instructed by the owner or alternatively
they can be accumulated offshore say with a major international
bank where interest on deposit accounts is not subject to tax.
If the offshore company is managed from Panama, does it follow that
the merchandise has to be sent there?
No. The merchandise can be sent directly to the exporter's client.
The services are performed in Panama, which has the second largest
by volume free-trade zone in the world at Colon, so in fact for
certain companies there may indeed be a benefit to setting up a
physical operation in Colon. Import-Export is one of the major businesses
therefore of Panama, known as "the crossroads of the world",
so this the "bread and butter" local business. However,
for most of our clients, the only functions performed here in Panama
are the preparation and dispatch of the new invoice and the management
of the banking operations.
What happens if the owner should become incapacitated and the offshore
company at that time has in its name substantial assets such as
cash?
Assuming you ensure that your beneficiaries have access to the bearer
shares or other arrangements are made with the Shareholder Foundation,
then if such a case should occur, they would simply produce the
shares to the management company together with some sort of evidence
of your incapacitation and all control of the assets will be transferred
to them. There would be no transfer taxes, estate duties, or other
forms of taxation levied on the assets.
What other Functions will Sovereign Management Services S.A. provide?
Once the offshore company has been established, our company will
arrange for a post office box, telex, telephone, and facsimile service
available for use by the offshore company. The management company
will then begin re-invoicing.
What are the fees for re-invoicing? How do I determine whether such
an operation is to my financial advantage?
The set up costs are generally less than one would think which includes
letterhead, telephone, telex, facsimile, mail service, as well as
a Nevis or Panamanian or corporation. There will be a 2% charge
on all re-invoicing operations. Reasonable out of pocket expenses
are additional. Annual renewal fees are minimal.
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