Tax Efficient Offshore Structure

DRAKE SOLUTIONS / MAURITIUS OFFERING

Benefits of setting up a Global Business License Company

• Corporate tax at 15%

• Import /export trading qualify for 3% corporate tax rate

• There is no exchange control in Mauritius, no capital gains tax and no dividend withholding tax on local dividends.

• Stable political, investment and banking environment

• Ranked 13th globally for ease of doing business

• It is the main financial hub for business and investment into Africa

• Rated 1st in Africa for Good Corporate Governance

Benefits of a foundation

• A Mauritian Foundation is a legal entity with hybrid features of a company and a trust and is required to be registered with the Registrar. It is considered as a preferred vehicle to hold assets.

• A foundation resembles a company in that it is a body corporate (albeit without shareholders) with separate legal personality that owns its own property like a company.

• The Foundation can benefit from the wide network of Double Taxation Agreements (“DTAs”) in force in Mauritius by applying for a Global Business License with the Financial Services Commission of Mauritius and electing to be tax resident in Mauritius.

• Client will be the Founder of the Foundation. Client will also be appointed as Council member and an appointed Management Company will act as the Corporate Co-Council member on the Foundation in Mauritius.

• Client can use their South African Discretionary Allowance of R1 Million to inject funds into the Foundation. This can be done through an unsecured, interest bearing loan repayable on demand. Client can also increase this amount by applying to use their R10m annual Foreign investment allowance.

Benefits of a Mauritius trust

• Benefits of a trust include keeping the business assets and growth potential outside the South African estate.

• It allows client to invest in global equities through the trust, with additional long term benefits including no capital gains tax and 3% income tax on dividends and interest.

• Serves as a wealth preservation and succession planning vehicle.

• Hedge against devaluation of Rand –assets invested and kept in hard currency.

• Client can use their South African Discretionary Allowance of R1 Million or their Foreign Investment Allowance of R10 million to inject funds into the Trust. This can be done through an unsecured, interest bearing loan repayable on demand.

• Client will be the Settlor of the Trust. The appointed Company will act as the Corporate Trustee on the Trust. (Client cannot sit as trustee on the trust as this will be seen as a sham trust).

• Trust Income Tax Rate 15% on rental, royalties and other income

• Trust Income Tax rate at 3% on foreign dividend income and interest income

• Capital Gains Tax at 0 (%)

• Withholding Tax 0 (%)

• There is no inheritance tax or death duties in Mauritius.