Hoogewerf & Co | About
Background
Hoogewerf & Co was set up by Francis Hoogewerf, a UK chartered accountant, in 1970. Hoogewerf & Co practices as a “Réviseur d'Entreprises”, “Expert comptable”, domiciliary agent and international tax advisor.
Tax Enviroment
The EU, the OECD, and now the G20, in 2009, have clearly made “Tax Transparency& one of their priority objectives. Onshore countries such as Luxembourg, Belgium, Switzerland, Austria and offshore countries with bank secrecy were, in 2009, put on the “grey list”.
Many of those countries, including Luxembourg, have signed new tax treaties, and as a result are no longer on the “grey list”. Bank secrecy will no longer apply to “tax fraud”. There will be exchange of information.
Professional advisors, banks, and insurance companies must know their clients and the business they do. Compliance is important. The way forward is to use tax treaties backed up to substance. “It is better to pay a little tax rather than no tax”
Tax Consultancy
Hoogewerf &Co have always been cross border tax specialists, working with colleagues, tax lawyers and accountants all around the world.
Not only do Hoogewerf & Co. advise on tax structures they will also coordinate the constitution and administration of appropriate tax advantageous entities and companies, virtually anywhere in the world.
Luxembourg
Luxembourg being a crossroads between France, Germany and Belgium and having a very strong international reputation in banking and investment, is an ideal location in Europe to centralise cross border tax consultancy. Luxembourg's strength is also its language ability. Not only do most people speak French, German, Luxemburgish and English there are also strong local communities who speak Portuguese and Italian. Hoogewerf & Co has all these languages plus Spanish, Russian and Chinese.
Holding Companies
Luxembourg′s SOPARFI, the well known mixed holding company, is mainly used for traditional holding activities. The SPF is used for private family holdings.
SOPARFIs can often serve as investment vehicles for Europe and countries with which Luxembourg has concluded one of the more than 70 Income Tax Treaties.
Despite of its taxable status which grants the SOPARFI access to the Treaties as well as European Directives (Parent-Subsidiary, Interest & Royalties, Mergers, etc.), dividends received from and/or capital gains derived from the disposal of shares in qualified participations benefit from full tax exemption in Luxembourg under certain conditions.
Historically the SOPARFI has been recognized not only as an efficient holding vehicle but also as a flexible instrument for real estate investment in Central and Western Europe.
With the recently approved IP regime, the role of the SOPARFI for international operations is reinforced.
Following decision of the EC Luxembourg introduced a new type of pure holding company- the SPF.
Designed for individuals, family members and private wealth entities acting for one or a group of individuals, the SPF can be an alternative and/or complement to trusts and foundations within Europe as an interesting asset protection and tax efficient vehicle.
Its main purpose is the acquisition, holding and management of financial assets such as shares, bonds, fund units, hedge funds, structured products, options, warrants, indexes, currencies, etc.
The SPF benefits from a favorable tax regime being exempt from corporate income tax, municipal business tax and wealth tax as well as withholding taxes. It is therefore a vehicle of choice for small or large scale investors or wealthy families seeking flexibility and asset protection.
Onshore Companies and Tax Treaties
Hoogewerf & Cie specialise in advising on tax treaties. In particular there are certain onshore countries that have tax advantages that are complementary to Luxembourg such as:
Austria |
Malta |
Belgium |
Netherlands |
Cyprus |
Spain |
Hong Kong |
Switzerland |
Ireland |
UK |
Some countries offer tax free capital gains and dividends, others, such as the Netherlands and Luxembourg are interesting for royalties and of course low tax or no tax on trading income is useful.
It is important to show “substance” - proper staff and office facilities to benefit from certain tax treaties.
Offshore Companies
Offshore companies are generally tax free companies based in offshore financial centers. From a tax point of view these companies may often be “black listed” by certain OECD countries. On the other hand, being tax-free they are also “tax neutral” and can be very useful for purely commercial reasons. They offer commercial secrecy although offshore companies must be considered as transparent when it comes to “tax evasion”.
A number of offshore countries are at present signing tax treaties for the avoidance of double taxation. The Isle of Man comes to mind with a signed treaty with Belgium. Others will be doing the same. This should provide interesting solutions.
Hoogewerf & Co have a joint venture with “OCRA Worldwide” who are well known specialists in providing both offshore companies and onshore companies.
