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Offshore structure to minimise tax on mining profits

Viktor

Offshore Agent
Jun 12, 2011
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I am an Australian resident who owns the right to a share of profits from an American mine. Extraction of minerals from the mine has yet to begin. Currently the contract specifying my share of profits from the mine is under my name but I am considering having the contract to be rewritten to be under the ownership of a company which I have yet to set up in order to minimize my tax obligations. From research I have conducted so far it seems that forming a Cyprus Offshore Company would offer the lowest tax rates, in addition I would consider relocating to a country that imposes no taxes on foreign income. However, there are a few things I am uncertain about which I wanted to clarify:


1. Does Cyprus, or any other country for that matter, classify income from mining profits as royalties, interest or dividends?


2. Could I have the contract rewritten so that it is under the ownership of the Cyprus Offshore Company while still maintaining my anonymity? Is it even necessary to have the contract rewritten, could I simply write a contract that transfers my entitlement to profits to the Cyprus Offshore company?


While I'm okay with paying 10% on my profits, if anyone was aware of any other offshore structure that could offer lower tax savings than the one I have proposed I'd like to hear your response.
 
Last edited by a moderator:
1. Does Cyprus, or any other country for that matter, classify income from mining profits as royalties, interest or dividends?
Cyprus don't do that as far as I know, however, to be sure not to be taxed you can simply incorporate the company non resident then the Cyprus company won't pay any tax.

2. Could I have the contract rewritten so that it is under the ownership of the Cyprus Offshore Company while still maintaining my anonymity? Is it even necessary to have the contract rewritten, could I simply write a contract that transfers my entitlement to profits to the Cyprus Offshore company?
Best is to sign a new contract in the name of the Cyprus company to avoid any legal confusion and issues. As long as you appoint a Nominee director you will not sign yourself so you will stay anonymous.
 
foreign Royalties are not taxed in Cyprus is that correct?
 
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