Seychelles License Company (CSL) - anyone who has such an setup?

[rotaro]

Just learned about this here Offshore Company Forum - The Seychelles License Company (CSL) is a Tax Resident Company with DTA Access. - Now I was wondering if there is anyone who actually has registered a Seychelles CSL company?


Is it as beneficial as it sounds and what are the costs for it?


Or would you still suggest to go for an Mauritius GBC1 company, any input would be appreciated.

 

[JohnLocke]

It depends very much on what your needs are, for instant Cyprus and the Seychelles have a Double Taxation Avoidance treaty which can be beneficial for the owner of such companies as for instant a Cyprus is now part of the EU whch the Seychelles isn't, now a Seychelles company can access the EU markets easily with the Cyprus Seychelles treaty.


Some of the many larger corporatons have an interest in investing in countries where no double tax agreement exists between the countries. In the above mentioned example an internmediary company is established in a jurisdiction with a suitable treaty. For instance, Cyprus has an extensive double tax treaty network with many Eastern European countries. The use of Cyprus companies for inward investment into these countries provides a tax efficient conduit.


When a overeas company directly makes an investment in a Seychelles Company, the withholding tax in the Seychelles will be 15% on dividends and 10% on interest on investment made within the Seychelles. Now here comes the catch..... When the investments are made in the Seychelles by a way of loan or capital through the Cyprus company, the payouts made from the Seychelles in form of dividends or interest is tax free, due to DTA Treaty with Cyprus and vice versa.


A Seychelles company has made investments in countries like India, CIS countries or outside of EU with whom Cyprus has treaties very easy and simplifies the entire process. Payouts from a Cyprus Company will be at 0% Tax rate due to the DTA of Cyprus with the Seychelles or any other country that Cyprus has a treaty with. Dividends or interest received by the Seychelles Company will have 0% withholding tax as there is no deduction at source in Cyprus on payouts made to a non-resident.


Useful information: Cyprus companies can incorporate mutual funds in the Seychelles for investments to and from EU and CIS countries, as well as to reach out to countries like South East Asia where the Seychelles has favourable double taxation treaties.


As you may see, there is not really any benefit any longer to have a Mauritius GBC1 company for this purpose, it has been replaced by the Seychelles CSL companies by now.

 

[flofi]

Does this also apply for regular Seychelles IBC's ?

 

[JohnLocke]

Sorry no, a Seychelles CLS is a company with special license to conduct business in the fields of Investment adn advice, re-insurance,interlectual property and franchise, offshore banking (maintain virtual accounts), holding company further a Seychelles CSL company is allowed to operate under the Seychelles International Trade Zone license.


Those are all benefits which a regular Seychelles IBC company don't has, however, many do not need the benefits a Seychelles CLS offers.

 

[clowdi]

From what I read it is a very efficient way to do business for UK business and most other European counties if they have any activity in China or India as well as a few other countries which are not part of the US or Europe.


What I read is that if you have the following construction in the order shown:


Parent company to be a UK


Seychelles CSL


Chines company


Net dividend for the Seychelles CSL would be 71.25% of the profits which then can be transfered as dividend to the UK company to be taxed 28%


This looks okay to me, but what I also read is that if you have a Cyprus company inbetween this setup you can get the dividend to 0% if structured correctly.


Really something one should look into.

 

[clemens]

Looks like a great alternative to the Mauritius GBL1 companies which have been the prefered choice by many chinese and Indians...


Mauritius GBL1

As defined under the Financial Services Development Act 2001, a GBL1 is a company engaged in qualified global business and which is carried on from within Mauritius with persons all of whom are resident outside Mauritius and where business is conducted in a currency other than the Mauritian rupee.


It is the recommended structure for individuals, body corporate, trust or partnership including limited liability partnership or a société for investment and other high profile business. A GBL1 may be locally incorporated or may be registered as a branch of a foreign company. Public companies, those engaged in banking, insurance and fund management, and companies wishing to benefit from the provisions of Double Taxation Agreements (DTAs), can only be incorporated as GBL1 companies.


Confidentiality is strictly observed in terms of the FSD Act. No person or body is authorized to disclose information or present documentation to any court, tribunal, committee of inquiry or other authority in Mauritius unless ordered to do so by a Court of Law on application by the Director of Public Prosecution for inquiry into the trafficking of narcotics and dangerous drugs, arms trafficking or money laundering as defined under existing legislation. Upon application to the FSC, full disclosure is required on the beneficial owners of the company. However, such information is not available for public inspection.

Would be interesting to hear if someone managed to register for a Seychelles CSL company, as I read the requirements are not that complicated but still it is easier to register a regular Seychelles IBC!

 

[rotaro]

I was in progress doing so, but I ended up with a Seychelles Mutual Fund. Sorry can't tell you how it is with the Seychelles CSL.