A professional adviser firm specialized in Corporate Services that has a global vision of the market and business and regards its client’s needs at the development of activities in the international environment.
Our mission is to offer advice to investors on legal and financial issues as well as in tax and market strategies, in order to obtain the greatest advantages and the highest profits.
Our members, specialized and independent professional work thoroughly to satisfy our clients.
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Arrange business activity, investment and heritage formation so that it incurs the lowest possible tax burden in order to maximize the return on investment.
To ensure this, we study the tax and legal framework in the different countries, choosing those that provide the investor a greater set of benefits, seeking a balance between profitability, legal certainty and tax burden on corporate profits, dividends and capital gains.
Tax optimization is achieved through a combination of legislation (civil, commercial and fiscal) of the selected countries.
Enable the investor to access the benefits of investing in countries with lower taxation, channeling business and investment overseas (import, export, creating and controlling shareholder of companies, equity investment) throughout the countries that offer better tax treatment.
Prevent profits, dividends, income or capital gains on foreign investments or in Spanish investments to be taxed in different countries at the same time.
The aim of Tax Optimization and Planning is to reduce taxation on businesses, professionals and investors.
Key feature of tax optimization is the compliance of the legislation of the countries through which it operates.
Hong Kong -The Gateway to Asia
A law firm specialized in Corporate Services that has a global vision of the market and business.
Our mission is to provide advice to companies on legal and financial affairs as well as in tax and market strategies, in order to obtain the greatest advantages and the highest profits.
Our professional members specialized and independents, work thoroughly to satisfy our clients in developing their businesses internationally.
Professional assistance for subsidiaries formation in Hong Kong. We believe that the presence in Hong Kong of the Chinese and Asia market-oriented firms is a strategic decision for the development of business in this dynamic economic zone.
Research and Select distribution channels for Spanish and Latin American products in the Asian market We want to be an effective tool for Spanish and Latin American exporters. From our office in Hong Kong, we have privileged access to the contacts needed to enter the Asian and Chinese market.
Promotion of Chinese enterprises in Spain. The establishment of a subsidiary or branch of Chinese companies in Spain, as a Member of the European Union, facilitates access of Chinese products to the entire European market (over 500 million consumers). The EU has Free Trade Agreements with many countries in Latin America (over 300 million consumers). From our office in Spain, we offer a wide range of corporate services to Chinese enterprises to help them develop their business in Europe and Latin America
AMKAL HK provided services are:
Financial and Strategic business planning.
Legal and tax advice
Establishment of subsidiaries or branches in the most advantageous jurisdiction
Business Management and administration with lowest tax and operating costs
Accounting and Auditing
Repatriation Benefit with the lowest tax cost
Benefit Reinvestment optimizing profitability and the tax burden
Repatriation and Reinvestment of Benefits
The legitimate purpose of any entrepreneur or investor is to obtain the highest return on investment. The investment process concludes once the benefits after taxes produced by their investments are obtained.
The repatriation of Earnings should not be understood nor treated as an isolated action of the investor, but rather a link at the end of a long process, starting with the investment Project, the effective realization of the investment, the business development and the achievement of surpluses or profits from operations.
Repatriation of earnings embrace a wide range of financial practices, before Income Tax, designed to allocate funds to its parent company operating in the country of origin.
Such common practices are the payment of royalties, commissions and interest, provide services and the supply of raw materials and equipment. Payments for these concepts are profusely regulated by the tax authorities of countries where the subsidiary or branch of the parent company operates; therefore, there are legal boundaries to prevent the abuse of transfer of funds into the parent company.
Among the most widespread regulations for transactions between parent and subsidiary, the demand for fixing the transfer price and not exceed certain percentages of income, may be considered abusive or not correlated with the activity or size of the subsidiary; in addition, to the taxation supported and the non-deductibility as expenses when computing the Income Tax.
On the basis of the above, the actions to plan by the investor or entrepreneur, must take no connection between the parties involved. In the case of international trade operations, companies can resort to centralizing procurement, distribution and logistics, based in low tax jurisdictions.
The process to obtain a net profit subjected to be repatriated is complex and ends, apparently, with the corresponding tax clearance that determine the % of the benefits that it has to be paid to the government, remaining the net income for the owner of the company. However, foreign-owned companies are subject to an additional tax on those net profits before allowing the earning repatriation.
Therefore, it implies that those benefits are eligible to be taxed again, once they return to the country of origin if a Double Taxation convention among the countries does not apply. Throughout different stages, the benefit decreases as it meets the subsidiary tax authorities’ requirements until it gets to the status of disposable for the investors.
The planning of business and investment activity has to be done very precisely from the beginning. The legal and tax framework of the country of the subsidiary has to be studied so the legislation requirements are rigorously meet.
Furthermore, we look for the corporate structure that offers the best tax treatment for the parent company´s revenues from dividends.
It is also needed, the study of the corresponding INTERNATIONAL DOUBLE TAXATION CONVENTION (TDC) that the host country has subscribed with the country chosen for the establishment of the subsidiary. The TDC is of great significance in order to reduce the tax burden, since it constitutes the Government agreements to avoid pay taxes on income twice in different countries. Choosing the location will take into account all these factors that directly affect business profit, the ultimate objective of all economic activity.
Reinvestment of benefits
Having determined the net benefit available and repatriable, is appropriate to study its use so that the new production cycle of these funds benefit from the planned financial and tax optimization.
In this phase, it will be crucial to design the most appropriate corporate structure (ex. Holding or an investment fund based in a low tax jurisdiction) to channel the flow of capital into the country of origin, in the form of investing or financing, that is as capital or loan, avoiding the payment of dividends when they are heavily taxed in the headquarters of the subsidiary and the parent.
The Planning oriented to financial and tax optimization is a sophisticated set of measures to reduce the tax burden of profits.
Such actions are “tailored”, varying substantially depending on the type of activity (manufacture, import, export, brokerage, provide services, operations in securities markets, etc..) as well as countries of origin and destination of the investment or business activity.
CAPITAL GAINS AND HEREDITARY SUCCESSION
May not be forget when tax optimizing, forecasting the future taxation of capital gains obtained by the transfer of shares in the case of disinvestment. Planning the hereditary succession of the owner of the business, so that gathers the will and produce the lowest tax cost for the heirs.
The most appropriate corporate structure, so that the final transfer of ownership of the company occurs by the simple transmission or endorsement of the holding´s securities, so is implemented in titles that do not have the status of public document, consequently, is not require the intervention of a notary. The most appropriate jurisdiction for this, the Anglo-Saxon Britain and the U.S.
To conclude, the catalog of solutions to apply is wide and requires personalized study by our technicians.
Calle Valle de Ayora, 25 bajo
Valencia (Valencia) España