Question loan capital to non-dom residents

[aragon]

Hello,

Does anyone have knowledge in how non-dom jurisdictions treat loan capital that is paid to non-dom residents, especially when said loans are collateralised with undistributed corporate foreign income?

And in particular with differentiation between loan capital that is:

1. Remitted into the non-dom jurisdiction, vs.
2. Remitted and left outside of the non-dom jurisdiction.

From the scraps I can find online it looks like the UK will want to tax this capital as foreign income in the case of (1), but I'm not sure about Malta and Cyprus. In the case of (2), I get the impression that all the non-dom jurisdictions don't care.

 

[CyprusLawyer101]

By loan capital you basically mean loans. Correct ? Normally no such income is taxable to start with , unless its something I do not understand.
In the case that this is foreign income , Cyprus would exempt it in both cases, whereas Malta exempts if not remitted.

 

[Gediminas]

Hello,

Does anyone have knowledge in how non-dom jurisdictions treat loan capital that is paid to non-dom residents, especially when said loans are collateralised with undistributed corporate foreign income?

And in particular with differentiation between loan capital that is:

1. Remitted into the non-dom jurisdiction, vs.
2. Remitted and left outside of the non-dom jurisdiction.

From the scraps I can find online it looks like the UK will want to tax this capital as foreign income in the case of (1), but I'm not sure about Malta and Cyprus. In the case of (2), I get the impression that all the non-dom jurisdictions don't care.

Hey,

It depends on the nature of the foreign income.

Capital gains and dividends are not taxable in Cyprus (for non–dom residents), and if you receive a loan first and then set it off against dividends or capital gains, it is not taxable whether you remit it to Cyprus or not. Other kinds of income in most cases would be taxable.

As per Malta, I suppose the second option (if not remitted to Malta) would not be possible, but again.. more circumstances have to be examined.

Why not move to Dubai, where it will not be taxable at all without any risks or questions?