Brazil Commercial BEPSibefsp.com.br/wp-content/uploads/2017/03/ApresentaÃ§Ã£o-Brazil... · Serving corporate but also high-net-worth-clients ... Estate Planning Amicorp Bank and

Brazil Commercial BEPS

Copyright Notice: ©2015 Amicorp Group. All rights reserved. The contents of this presentation have been prepared by the Amicorp Group A.G. for informational purposes only. The information contained in this

presentation does not constitute or contain any type of advice, and neither our presentation of such information nor your receipt of it will create a commercial or legal relationship. Consequently, you should not

act or rely upon the information contained in this presentation without seeking professional counsel. The information presented in this presentation, the access to the information contained herein or your receipt

of it will not create any service provider-client relationship. Amicorp Group A.G. is the owner of all copyright and other rights in and to all copyrightable text and graphics on this presentation. Your company or its

representatives may lawfully use this presentation for its own, non-commercial purposes, by displaying this copyright notice. Any other reproduction, copying, distribution, retransmission or modification of all or

any parts of this presentation is strictly prohibited without the express prior written permission of the Amicorp Group.

Trademark Notice: The Amicorp word and device are trademarks of Amicorp Holding Limited. All rights reserved.

www.amicorp.com

Amicorp do BrasilRua Helena 260 -14º andarVila Olimpia – São Paulo - SP

Introduction to Amicorp Group www.amicorp.com

Amicorp Group• Who are we

2

An independent growing global provider of company secretarial and

fiduciary services

Serving corporate but also high-net-worth-clients

Hong Kong based group - established in 1992

Emerging markets: Latin America, Eastern Europe & Asia

Global networked team

ISO 9001, ISO 27001, SAS 70 type II & ISAE 3402 type II, Six Sigma

Licensed & regulated corporate, trust and fund provider

Strict compliance policies, compliant solutions

Secure systems with backups in Geneva

Introduction to Amicorp Group www.amicorp.com3

Amicorp Worldwide Offices

The Americas

• The Bahamas

• Barbados

• Bogotá

• British Virgin Islands

• Buenos Aires

• Cayman Islands

• Curaçao

• Lima

• Mexico City

• Miami

• Montevideo

• New York

• San Diego

• Santiago

• São Paulo

Europe & Africa

• Amsterdam

• Barcelona

• Cyprus

• Johannesburg

• London

• Luxembourg

• Malta

• Mauritius

• Monaco

• The Seychelles

• Vilnius

• Zug and Zurich

Asia & Pacific

• Auckland

• Bangalore

• Davao

• Dubai

• Hong Kong

• Mumbai

• New Delhi

• Shanghai

• Shenzhen

• Singapore

• Taipei


Amicorp Group• OUR business – OUR specialization

4

Entity Administration Services

Establishment and administration of companies, trusts,

foundations

Company formation and management services

Private clients services

Corporate client services

Outsourcing Services

Accounting, Legal and IT outsourcing

Financial support services

Fund administration


Our Client Focus• Delivering high quality through our client partnership model

5

01We evaluate our clients specific

needs and create customized and

compliant solutions to fulfil them

02With around 16.000 clients, we

represent some of the most prestigious

banks, law firms, multinationals

and asset managers in the world

03A high client retention rate,

greater than 93%, testifies to these

long-standing relationships

04Building relationships built on

mutual respect and trust that last

for generations

Personalized service, local experience and networks

Specialized professionals with local tax legislation knowledge

Experience in major top global markets

Hands-on offering practical solutions

Transparent fee schedules


Our Services

6

01Corporate

Client Services

04Director and

Shareholder Services

02Institutional

Sales Unit

05Compliance and

Regulatory Services

03 Company Formation

and Management

06FATCA

Services

Deliver the broadest range of

structuring alternatives involving

corporate vehicles such as

companies, partnerships and

foundations. We assist with risk

management and the simplification of

global operations.

Lead the engagement with private

banks, family offices, accounting and

legal firms and independent financial

advisers. We deliver trust and fiduciary

solutions including asset protection, tax

planning, business and family

succession planning.

Establish and administer all types of

corporate entities. Provide all

supporting services related to company

management and administration

services.

Provide corporate directors or other

relationship services relating to the

holding of clients’ entities in a range of

jurisdictions. We supply a variety of

services that ensure strict compliance

with tax laws.

Assist our clients in managing the ever

increasing complexity they are faced

with:

· Compliance policy procedures – AML

framework

· Regulatory inspection readiness

· Regulatory remediation.

Comply with US FATCA and the

announced global FATCA regulations.

To ensure clients are FATCA compliant

we provide the following services:

classification, registration, sponsorship,

identification of US persons, reviewing

existing structures for compliance, etc.


Our Services

7

07Financial

Services

10Fund Structuring and

Administration

08Trust and Private

Foundation Structures

11Outsourcing

Services

09Estate Planning

Amicorp Bank and Trust (ABT),

provides tailor-made financial

products and business solutions.

AmiLife: Single Premium Life

Insurance

Amicorp Insurance Company (AIC)

offers a captive insurance program.

Used as the top entity in private or

corporate investment holding

structures, we provide establishment,

management and administration

services as well as trustees and

directors.

We establish and administer estate

planning structures. We provide private

office services that are independent

from any asset management relations

the client has.

We set up the right structure in the right

jurisdiction. We obtain regulatory

approval, draft prospectuses,

resolutions and all related agreements.

ISAE 3402- certified fund administrator.

Our multiple services include:

Scanning and document handling

Finance and accounting (including

internal and client administration),

investment portfolio administration,

payroll administration, compliance and

IT hosting.


Corporates: Global Business Trends in 2017

Emerging Markets for Global Business

Industries of focus for Global Business

Demographic Shifts, Reverse innovation and Mass customisation

Innovation & Communication

Increased Competition & Slower Growth

Trade reclassified: The falling cost and rising speed of trade

DRAFT - 30 Jan 2017


Corporates: Top global business risks for 2017

SOURCE: The Allianz Risk Barometer

Changes in legislation

and regulation(government change, economic

sanctions, protectionism, etc.)

Macroeconomic developments(austerity programs, commodity

price increase, deflation, inflation)


Tax Compliance & Assurance

SOURCE: The Allianz Risk Barometer

GLOBAL TRENDS

1. AEOI : FATCA and CRS

2. Tax as Criminal Offence – next also banks and providers

3. VDP – Tax Amnesties as last resort

4. More focus on POEM and Substance

5. BEPS – Base Erosion Profit Shifting and other anti abuse

Abuse of Tax Treaties – LOB and PPT Transfer Pricing and Documentation Transparency and self disclosure


Why do Corporates Do International Structuring

For Any business enterprise a tax burden (necessary or

unnecessary) represents a business wastage which creates

impact on distributable profits and reduces competitive

effectiveness

Globally Local Tax laws hence compete with each other to be

preferred jurisdiction of choice on following major counts

Which Business Activities are subject to local taxations

At what rate is the Business Activity taxed ?

At which point of time / instance is the Business activity

taxable ?

PROFITS

LOSSES/

EXPENS

ES

No Tax Event

Lowest Tax Rates

Deferred Taxation

Private Event

(NO)

Highest Tax Rate

Immediate

Deduction


BEPS: Base Erosion – Profit Shifting

UK and EU started, OECD and G20 took it global

Combat tax avoidance structures of Starbucks, Amazon,

Apple, etc

Base Erosion by exploiting gaps / loopholes

Profit Shifting to low tax counties

Most schemes are legal. Most artificial, but abusive with low

ETR.

OECD says it distorts competition, and shifts activities.

Citizens more sensitive to “tax fairness”.

BEPS Action Plan, developed by OECD early 2013

BEPS


BEPS Readiness (Around the World)

13

13SOURCE: Thomson Reuters


Why Should Global Corporates Review Immediately ?

SOURCE: Slideshare

Withholding tax leakages Hybrid financing structures

Funding arrangements Transfer pricing structures

Commissionaire structuresTransfer pricing documentation


Why Should Global Corporates Review?

SOURCE: Slideshare

Map Legal Entities and Their Tax Residencies

Map Employees and Their Roles

Obtain Entity Level Financial Data

Business Operations and Transfer Pricing Policies

Local File Access Resources and Data


Starbucks, Microsoft, Apple using loopholes

16

16


Tax strategies: Base Erosion & Profit Shifting

17

Common planning strategy of MNC re BE & PS:

Erode taxable basis and shift profits from high tax to low tax environment

Complex and not transparent

Main Holding Co/Operating Co

Regulated Fund (Whitelisted)

Operating Co in A & BSourcing & Sales centers in D & E

Joint Venture Entities Treasury Centers Savings on Local WHT for “Dividends and Interest”

Investments via Tax Treaty Based Structures

No Tax Treaty Based


Case Studies: Developed Market Company (Financing Structures)

Holding Co (UK)

Holding Co (UK) Holding Co (Swiss)

Op Co (Swiss) Fin Co (Dubai) Fin Co (BVI)

Fin Co

(Mauritius)

Op Co (Nigeria)

Op Co

(Canada)

?

?

?

?


Case Studies: Developed Market Company (Restructured by Combining Operational and Legal Structures)

Holding Co (UK)

Licenced Fin Co (UK) Holding Co (Swiss)

Op Co (Swiss)

Op Co (Nigeria)

Op Co

(Canada)

Board of Directors and Group CEO

Management Committee

(Accounting and Risk)

Group CFO &

Corporate

Treasury

Chief Risk

Management and

Quality Control

Local Office of

CEO &

Operations

Local Office of

CEO &

Operations

Local Office of CEO

& Operations

Book Keeping

and Audit

Book Keeping

and Audit

Book Keeping and Audit


Case Studies: Emerging Market Company (Tax Treaty Driven)

Holding Co (India)

Holding Co (Singapore)

Op Co

(Singapore)

Fin Co

(Singapore)

Fin Co

(Singapore)

Op Co

(Indonesia)

Hold Co

(Philippines)

JV Op Co

(Philippines)

JV Op Co

(Maldives)

?

?

?


Case Studies: Emerging Market Company (Restructured on Principal Purpose)

Listed Holding Co (India)

Holding Co (Mauritius)

Multi Class Fund (Singapore)

Op Co

(Indonesia)

Hold Co

(Philippines)

JV Op Co

(Philippines)

JV Op Co

(Maldives)

Licenced Corporate

Treasury Co (Singapore)

Asia CFO &

Corporate Treasury

Investment Manager

to the Fund

Asia CEO & Business Development Team

Local JV

Representative Local CEO / CFO /

Operations Team

Local JV

Representative

(Finance)

Local JV

Representative

(Operations)

Management (Operations)

Independent Fund Administrator


Corporate Client Services

22

Amicorp’s corporate clients unit leads our engagement with professional intermediaries (legal, tax and

financial advisors), publicly and privately held multinational corporations, small and medium enterprises,

startups, and pension plans in multiple jurisdictions.

Our in-depth knowledge of local and international accounting standards and local compliance processes

(legal, accounting, payroll and tax), provides significant time zone, cultural and language advantages. In

addition, our experts are experienced in international matters related to double taxation, investment

protection, transfer pricing, trade economic zones, intellectual property registration, and international

institutions and groups (such as the OECD, G-20, EU, and NAFTA).


Amicorp Team

Fabio Rabelo - Manging Director at Amicorp do Brasil

[email protected]

Tel. +55 11 9.918-3572

Ricardo Sitzer - Senior Manager Sales at Amicorp do Brasil

[email protected]. +55 11 9.9169-3948

Deabashish DasGupta – Head of Corporate Clients at Amicorp Group

[email protected]. +971.4.304.2900

Thiago Lour – Senior Manager Sales at Amicorp do Brasil

[email protected]. +55 11 9.9248-8875

mailto:[email protected]





Thank You Copyright Notice: ©2015 Amicorp Group. All rights reserved. The contents of this presentation have been prepared by the Amicorp Group A.G. for informational

purposes only. The information contained in this presentation does not constitute or contain any type of advice, and neither our presentation of such information

nor your receipt of it will create a commercial or legal relationship. Consequently, you should not act or rely upon the information contained in this presentation

without seeking professional counsel. The information presented in this presentation, the access to the information contained herein or your receipt of it will not

create any service provider-client relationship. Amicorp Group A.G. is the owner of all copyright and other rights in and to all copyrightable text and graphics on

this presentation. Your company or its representatives may lawfully use this presentation for its own, non-commercial purposes, by displaying this copyright

notice. Any other reproduction, copying, distribution, retransmission or modification of all or any parts of this presentation is strictly prohibited without the

express prior written permission of the Amicorp Group.

Trademark Notice: The Amicorp word and device are trademarks of Amicorp Holding Limited. All rights reserved.

www.amicorp.com

Amicorp Group

Rm. 2103-4, 21/F, Wing On Centre,111 Connaught Road Central, Hong Kong

Fax: +852 3105 9883 Tel.: +852 3105 9882

email: [email protected]

Amicorp Limited

Documents

Brazil Commercial BEPSibefsp.com.br/wp-content/uploads/2017/03/ApresentaÃ§Ã£o-Brazil... · Serving corporate but also high-net-worth-clients ... Estate Planning Amicorp Bank and