Trusts

In most Common Law jurisdictions estate planning may include the use of  Trusts.

However, in most European countries the legal system governing estate planning is very different, and will most probably include ‘forced heirship’ laws and the imposition of succession or gift taxes (which are paid by the beneficiaries, the settlor or even both).

Some countries would not recognize the legal system of Trusts and did not enter into “The Hague Trust Convention” – an international agreement on the Law Applicable to Trusts and on their Recognition. The use of Foundations (Stiftungen) is more common.

In such cases, all Trusts Assets are deemed to be personal assets of the Settlor if it comes to Wealth Tax.

Expats who temporarily move abroad may face not only the complexity of a foreign tax system; they may also remain liable to some taxes at home. Hence International Tax Planning is essential to avoid unnecessary double taxation.

For most of our clients, the most valuable advice provided by us is based on our deep understanding of tax systems in various countries, enabling us to point out the interaction between the country of residence and country of domicile (often in Common Law Jurisdictions). In any way it is possible to end up in a Tax Residency in one or more countries, triggering Tax Liabilities in each country.

Through our scope of work in International Taxation we offer a seamlessly integrated second to none international and local tax advice – always backed up through local partners. We cover the full range of Taxation – Income Tax, Capital Gains Tax, Gift & Inheritance Tax and Wealth Tax.

Speak to us prior to moving abroad to discuss the complexity of Tax Residency.

Different countries have their own tax laws. If you are a resident in one country and have income and gains from another, you may have to pay tax on the same income in both countries – or none of them. DTA – Double Taxation Agreements aim to avoid ‘double taxation’ or double non-taxation.

For example, an individual who is resident in Belgium, but has rental income from a property in another country, may have to pay tax on the rental income in both in Belgium and that other country.

To avoid double taxation (and of course a double non-taxation), many countries entered into Tax Treaties (DTA – Double Taxation Agreements), mainly based on international OECD-Standards.

Therefore it is important to plan a tax structure BEFORE entering into any agreements abroad that may trigger tax issues.

First Advisor (CCSA) is a professional team of Experts, specialized in International Taxation and focussed in Tax Consulting & Advisory with international experience. Hence we will bring you valuable high-end expert advice.

We take care of the whole process, from Accessing your personal circumstances, Tax Consulting and Advisory to suit fit your needs and implementation of better suitable structures.

We offer an initial Consultation (up to 15 minutes) free of charge via Skype.