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Welcome to the latest Appleby Finance Offshore quarterly newsletter. Finance Offshore is designed to bring you up to date with latest changes to the law, trends and useful information in relation to the finance industry.
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PRACTICE UPDATE
OFFSHOREQ4 2014
FINANCE
CONTENTS2 Jersey Insurance Business Transfer Schemes 4 30th Anniversary of the BVI International Business
Companies Act 1984 6 Why Offshore Corporate Structuring Needs to be on the Agenda8 Long-overdue Changes to the Companies (Jersey)
Law 1991 10 New IOM Regime for Foreign Companies
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Insurance practitioners planning a merger or acquisition need to consider when part of the target’s business is conducted in Jersey that it is likely that the jurisdiction of the Jersey courts may overlap with the jurisdiction of foreign courts and that a Jersey scheme of transfer may be required in order that the business transfer is recognised in Jersey.
If a Jersey Scheme is Required?Where it is proposed to transfer the whole or part of an insurance business carried on in or from within Jersey by a permit holder under the Insurance Business (Jersey) Law 1996 (Insurance Law) to another permit holder or insurer, a Jersey court-sanctioned scheme of transfer under article 27 of the Insurance Law is required.
The carrying on of insurance business in or from within Jersey includes:
“obtaining or seeking to obtain such business from a person incorporated, registered or resident in the island by means of a contract or arrangement with another person where: the sole or principal purpose of such a contract or other arrangement is the obtaining or seeking to obtain such business; and that other person gives effect to the contract or other arrangement in or from within the island.”
The test for what constitutes carrying on insurance business in the Island mirrors the criteria for determining whether or not a Jersey insurance permit
JERSEY INSURANCE BUSINESS TRANSFER SCHEMESDanny Cole
is required by an insurer. Therefore, it is usually safe to conclude that the Jersey courts will (subject to very limited circumstances) have jurisdiction in relation to a scheme to transfer business conducted by a Jersey insurance permit holder. Insurers should seek legal advice as to whether a proposed novation of insurance business represents a transfer of insurance business to be addressed through a court-sanctioned scheme pursuant to article 27 of the Insurance Law.
Jersey Scheme Procedure A Jersey insurance transfer scheme must be sanctioned by the Royal Court of Jersey.
The Insurance Law provides that a transferor party to a scheme is required to hold a permit issued by the Jersey Financial Services Commission (JFSC). Although the Insurance Law does not require a transferee party to a scheme to hold a permit, the JFSC will require a transferee to hold a permit prior to the transfer to it of business carried on in or from within Jersey.
Transfer Scheme Documentation In order to consider a transfer scheme, the Insurance Law requires that the following documents are provided to the JFSC:
1. A Representation (a Jersey form of pleading), which commences the application;2. Independent Actuary’s Report;3. Jersey Transfer Scheme Document;
According to a report earlier this year published by Grant Thornton (Global Insurers – Mergers & Acquisitions) “… improved macroeconomic conditions in developed countries, allied to the availability of attractive financing options is having a positive effect on [insurance] firms’ appetite to re-enter the M&A market.” They also suggest that domestic consolidation has emerged as a key theme in developed markets. We have witnessed more activity and consolidation in recent years in the insurance sector, particularly in Appleby’s Guernsey, Isle of Man and Jersey offices.
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“A Jersey insurance transfer scheme must be sanctioned by the Royal Court of Jersey.”
4. Affidavits/witness statements;5. Policyholder communication documents;6. Legal Notice to be published in the Jersey Gazette stating that the application has been made; and7. For Category A Permit holders under the Insurance Law the name and contact details of the principal contact for the overseas regulator that is considering the associated overseas transfer scheme.
Copies of the Representation and the independent actuary’s report must be available to inspect or collect for at least 21 days beginning on the day that the Jersey Gazette notice is first published. First Hearing (Royal Court of Jersey) – DirectionsParagraph 4(b) of Schedule 2 to the Insurance Law requires that a statement be sent to each policyholder and every member of the transferor and transferee of the scheme unless otherwise directed by the court. Such requirements can be extremely onerous on insurers where, for example, it may not be possible to definitively contact all policyholders or if the transfer will not materially affect the transferee’s business. Invariably then, directions are sought from the court to dispense with the strict notification requirements.
The JFSC are afforded the right to speak at each court hearing and make objections to the proposals sought. The court when considering the directions sought will take comfort from the JFSC’s stance, and so it is vital that the JFSC are provided with details of any waivers sought, the rationale for such requests and the number of Jersey policyholders. Provided the JFSC is satisfied, they will provide a letter of no objection to the parties seeking a transfer.
Second Hearing (Royal Court of Jersey) - Scheme SanctionAssuming the Directions sought at the first hearing are granted and the notification requirements (as varied at the Directions Hearing) have been followed and the JFSC have maintained their stance of no objection, the Second Hearing should be more of a formality than the first, as the Scheme and its impact would have already been considered by the court.
Appleby ExperienceAppleby have considerable expertise in relation to Jersey insurance transfer schemes and are often instructed by insurers carrying out multi-jurisdictional acquisitions in conjunction with our colleagues in Guernsey and Isle of Man, as Appleby is the only law firm practising in all three Crown Dependencies and has unparalleled insurance expertise in its Bermuda office. Large insurers often operate in all three Crown Dependencies and benefit from the continuity of our service.
The banking and asset finance team at Appleby have also drawn on our insurance team’s experience by using analogous transfer procedures in landmark court-sanctioned banking business transfer schemes in Jersey.
CONTACT
JerseyDanny ColeSenior AssociateCorporate & Commercial+44 (0)1534 818 [email protected]
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The 1984 introduction of the IBC and its successor, the BVI Business Companies Act 2004, have paved the way for the BVI to become a global leading international financial centre, particularly in the arena of company incorporations.
History The creation of the IBC was ignited by the USA and UK unilaterally terminating their respective tax relief treaties with the BVI in 1981. The loss of revenue, particularly as a result of the termination of the US treaty, had an almost immediate direct negative impact on the territory. The indirect positive repercussions to the BVI were to be broader and have greater significance than most would have imagined at the time.
The germination of the development of the territory as an international financial centre (IFC) had, however, occurred some years earlier. In 1976 Paul Butler, a partner at the Wall Street law firm Shearman & Sterling had explored and subsequently pioneered the structuring of transactions employing BVI vehicles.
In the early 1980’s the newly appointed BVI Attorney General, Lewis Hunte, together with Paul Butler and a team of bright energetic BVI lawyers, realised that to build on the growing attractiveness of the BVI as an IFC, the BVI needed to offer an innovative, flexible and business-friendly corporate vehicle as well as enhance corporate law legislation. Consequently, these individuals were the pioneers of drafting, reviewing and bringing into existence the new legislation in August 1984.
Legislation The IBC reflected recognition by its draftsmen of the impending developments in global corporate law. These developments included enabling these companies to acquire their own shares and provide financial assistance to others in acquiring their shares; abolishing the requirement for all corporate actions to be solely for the corporate benefit of the company (thereby recognising and enabling the development and use of the corporate group structure); removing the requirement for corporate capacity, ultra vires (thereby enabling these companies a great degree of flexibility in their operations and an ability to quickly adapt their operations to commercial developments); creating new mechanisms to achieve mergers, acquisitions and restructuring of these companies; and importantly creating an effective and efficient incorporation procedure allowing the quick establishment and commencement of operations of these vehicles. These provisions are common-place in the global modern corporate law arena but were revolutionary at the time of introduction in the BVI.
This quantum leap in BVI corporate jurisprudence was not a one-off event. The IBC was amended from time-to-time, albeit infrequently. One of the material amendments was to introduce a regime of security interest registration. This allowed charges, mortgages and assignments of interests in assets of BVI companies to be formally registered. This security
30TH ANNIVERSARY OF THE BVI INTERNATIONAL BUSINESS COMPANIES ACT 1984Jeffrey Kirk
15 August 2014 marked the 30th anniversary of the date that the International Business Companies Act 1984 (IBC) came into force in the British Virgin Islands (BVI). In terms of individual statutes worldwide, one would be hard-pressed to find an example of a similar law that has had such profound and positive implications for the jurisdiction in which it was promulgated.
PRACTICE UPDATE
CONTACT British Virgin Islands Jeffrey KirkManaging PartnerGroup Head, British Virgin IslandsCorporate & Commercial+1 284 393 [email protected]
Co-written by Heidi Maharaj, a senior associate in the corporate and commercial practice group of Appleby BVI.
“… the fact that the BVI corporate product appeals to such culturally diverse people … remains an enduring testament to the foresight and energy of those early pioneer draftsmen of this legislation …”
registration regime has been one of the contributors to BVI companies being widely used in banking and financing transactions by providing an effective security recording and publicity regime that provides substantial comfort and protection to lenders.
Post-millennium, a process of replacing the IBC was commenced. The rationale for replacement legislation was twofold. Firstly, it was deemed necessary to update and modernise the IBC, which had been based on Delaware corporate law, whilst retaining its essential business efficacy characteristics. Secondly, to respond to, and deal with, pressure from the OECD and other organisations that objected to IBC companies being incorporated within the BVI but not being subjected to local corporate tax, provided they conducted business outside of the BVI (‘ring-fencing’). Local BVI companies, termed ‘CAP’ companies, were subject to local BVI corporate tax as they conducted business and generated income within the BVI. The new legislation, the BVI Business Companies Act 2004 (BCA), which was based on New Zealand corporate legislation, therefore consolidated both forms of BVI corporate vehicles.
Global Appeal The global appeal of the BVI corporate offering cannot be understated. Shareholders in BVI companies are located in countries as diverse as China to Chile and New Zealand to Norway.
The positive uses to which BVI corporate vehicles are applied are numerous and varied. These vehicles have and continue to be used for projects such as listing a BVI company operating as a new town developer on the Hong Kong stock exchange or establishing BVI investment holding companies and funds for Middle Eastern investors or for South Korean asset managers.
As noted above, the BVI corporate security registration system has, in particular, proven attractive and has led to BVI companies being directly involved in the financing of alternative energy sources and clean water projects in the People’s Republic of China for an Asian development bank operating out of the Philippines.
ConclusionIn the final analysis, the fact that the BVI corporate product appeals to such culturally diverse people for such a myriad of purposes remains an enduring testament to the foresight and energy of those early pioneer draftsmen of this legislation and also of those men and women who have subsequently and tirelessly promoted the BVI as an IFC.
The future challenge is to further develop and diversify the BVI corporate offering, as well as other products and structures, so that the BVI continues to offer an environment that is conducive to, and facilitates, international business.
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Typically for small to medium sized companies, consideration of corporate structuring, let alone off-shore corporate structuring, has not been high on the agenda and generally assessed by “what works right now”. As is now obvious in the global market, the big players are truly international companies that use offshore corporate structuring as a competitive advantage. To keep up, companies need to put corporate structuring on the agenda and ask themselves “what will provide an advantage going forward”.
General Benefits of Offshore Structures The general benefits of utilising an offshore corporate structure can include:
■ Access to global funding: Offshore vehicles familiar to a company’s target investors and financiers can attract a wider pool of global investors and tap into the considerable funds currently in the offshore market;
■ New market entry: Gateway for international market expansion, facilitating both western companies’ investment and expansion in developing markets and also acting as a base for companies in emerging markets to attract investment at home and expand to western markets;
■ Asset separation/protection: Offshore ownership of IP can enable efficient international licensing and separation of core asset ownership from operating entities;
■ Stable and business centric legal systems: Generally common law based jurisdictions that are recognised globally, they provide streamlined,
WHY OFFSHORE CORPORATE STRUCTURING NEEDS TO BE ON THE AGENDA Oliver Lawson
From the fast paced and cash constrained environment of start-ups to the expansion challenges experienced by more established growth companies, raising capital and entering new markets are key focal points for companies.
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stable and flexible legal processes for raising capital, investing in assets and ultimately exiting through mergers and acquisitions or IPOs;
■ Tax neutrality: Financial benefits that come from tax neutrality on international earnings. Benefits from tax neutrality can come from no personal or company income tax, no capital gains and no inheritance tax on international earnings depending on the jurisdiction.
When selecting an offshore jurisdiction (more than one may be used) it is important to consider both current and future business objectives and understand which jurisdictions are favoured by your target future sources of capital and your target markets.
There is no single corporate structure that is best for companies at every stage of the funding cycle and a range of opportunities should be considered and aligned with the business’s objectives.
Seed Capital At the seed capital stage the corporate identity of the start-up becomes very important. Commonly at this point, a partnership or limited liability company is established in the founder’s home jurisdiction. Even at this stage, establishing a simple offshore holding structure in which to raise funds and split the ‘pie’ is beneficial as it establishes from the outset an offshore identity that can become the home for IP being developed, a base for future international earnings and it creates an entity that will provide on-going flexibility.
Angel Investment When looking to attract Angel investors (typically raising from US$100,000 to $600,000), establishing
CONTACT
Cayman IslandsOliver LawsonAssociateCorporate & Commercial+345 814 [email protected]
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As is now obvious in the global market, the big players are truly international companies that use offshore corporate structuring as a competitive advantage.”
an offshore structure can be of itself a financial advantage in the business plan due to tax neutrality of international profits that might be forecast. In any event, such a structure will provide greater flexibility to Angels to re-invest existing offshore funds in another offshore entity and widen the pool of potential Angels.
Venture Capital At the VC stage (typically raising US$500,000+), corporate structuring will most certainly be put on the agenda. Companies that have already established the basis of an offshore structure are likely to benefit from reduced restructuring costs and the existence of the offshore identity. Even more so than with Angels, an offshore structure could attract VCs from a wider audience and tap into funds seeking offshore investments with a route to operations in target markets or industries. Importantly, a well selected offshore jurisdiction will provide flexibility to set-up stock structures that are desired by the target VCs.
IPO and Exit Companies and investors who have planned their offshore structure ahead can typically leverage, at a lower cost, the full benefits of liquidating their equity and exiting through the sale or merger of an offshore entity, or by raising further capital and partial exit by way of IPO and public trading. Offshore entities also offer a relatively flexible capital structure as to conversion rights, super voting rights and employee
options pre and post IPO which are helpful to investors in IPO’s.
Creating a new offshore structure is also common at the IPO stage. In Asia particularly, usually the first step for an IPO is to establish an offshore holding structure and to utilise an offshore vehicle to access international public markets. The offshore vehicle then acquires, or acquires control, over the relevant operating company. By way of example, typically for IPO structures from the People’s Republic of China (PRC), Wholly Foreign Owned Entity (WOFE) structures are used to capture most of the economic benefit of PRC operators while protecting the economic interests of the offshore investors.
Market Expansion At any point in the funding cycle where companies are looking to raise funds to facilitate expansion across international markets, or even simply operate in new markets, offshore corporate structuring can be a valuable tool for all sides. Offshore structures can be leveraged by companies in developing markets to attract international investors by providing a vehicle that is understood by investors and provides the necessary asset protection, share structures and tax structure required by the investors. Depending on the target market for entry, key benefits of offshore structures go beyond the immediate financial benefits of tax neutrality on international profits and can provide an actual avenue to do business in restrictive markets and protect companies from some of the inherent jurisdictional risks of such markets.
Co-written by Simon Raftopoulos, a partner and the Group Head of Private Equity in the corporate and commercial practice group of Appleby (Cayman) Ltd.
This article considers the benefits and practical implications of the Companies (Amendment No.11) Jersey Law 2014 (the Amendment) in respect of deemed distributions, curing previously unlawful distributions, and ratification of directors’ other breaches of duty as well as a simplified procedure fir reduction of share capital.
The Upstream DebatePrior to the entry into force of the Amendment, it was necessary to consider whether an upstream guarantee or other similar arrangement could be a distribution. If, for example, a guarantee were given to guarantee the obligations of the sole shareholder of the guarantor, and the guarantee were to be called upon the next day, there would be little in the Companies (Jersey) Law 1991 (the Law) (pre-Amendment) to rule out the possibility that a distribution had been made (although the debate would inevitably rumble as to whether that were true where the guarantee was not expected to be called upon, as would normally be the case). Some directors were advised that it was not a distribution, entering into upstream guarantees on the basis of board minutes only, while other directors were advised (or required by lenders’ counsel) to be more cautious, and follow the solvency statement procedure set out in Article 115 of the Law.
The Amendment adds much-needed clarity to Article 115, making it clear that the restriction on distributions does not apply to a distribution which does not reduce the net assets of the guarantor. In normal situations, an upstream guarantee would not reduce the net assets of such a guarantor, and so we
now know for certain that an upstream guarantee does not trigger the requirement for directors to give the statutory solvency statement.
The CureWhile helpful in this regard, the Amendment only changed the Law going forward, it did not however settle the debate that existed under the old law in respect of transactions entered into before the Amendment came into force. Therefore, where an upstream guarantee was given or other deemed distribution made under the old law without an Article 115 solvency statement, it should be noted that the potential breach would not be cured by the Amendment. However, the Amendment does introduce a court application procedure whereby a previously unlawful distribution can be ratified. Whilst the ratification does involve a court application, which can be time consuming and costly, it does have the advantage of allowing the distribution to be treated as lawful at the time it was made.
Resolutions and RatificationsThe Amendment has also altered the law on ratification of directors’ breach of duty. Under the law prior to the Amendment, a unanimous authorisation of the shareholders under Article 74(2) was required in order to sanction or ratify a breach. A new Article 74(3) has been added allowing the same procedure to be carried out by ordinary resolution (or special resolution if the articles of association require). Furthermore, previous difficulties associated with the meaning of “unanimous” in the context of non-voting and other limited right shares have been removed.
LONG-OVERDUE CHANGES TO THE COMPANIES (JERSEY) LAW 1991Tom Fothergill
Until now, barely a week could go by for finance lawyers and trust company directors in Jersey without someone entering into a long-standing debate about whether an “upstream” guarantee could be a distribution for the purposes of Jersey Law. However, that has changed.
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CONTACT Jersey Tom FothergillAssociateCoporate & Commercial+44 (0)1534 818 [email protected]
“The Amendment provides further streamlining of the law through the introduction of a new, alternative procedure which enables companies to reduce their capital without having to go to court.”
On a related note, changes have been made to the regime for passing written resolutions, allowing for non-unanimity, and setting out the procedure for doing so. The articles of association of the relevant company can set different thresholds for different resolutions, adding a welcome degree of flexibility to companies, while still allowing for a welcome degree of protection for minority shareholders.
Reductions of Share CapitalThe Amendment provides further streamlining of the law through the introduction of a new, alternative procedure which enables companies to reduce their capital without having to go to court. This procedure requires a special resolution of the shareholders, to be filed with the Registrar of Companies, together with a supporting solvency statement by the directors (made no more than 15 days before the passing of the special resolution by the shareholders). Here another amendment is made to the (old) law in the requirements of the standard solvency statement. It now requires directors to be aware of, and consider the solvency of the company for a 12 month period going forward.
These amendments allow all types of company, whether public or private, to take advantage of this
new procedure. In relation to private companies this new process is a similar approach to that of the UK Companies Act 2006. As a result of these changes, a Jersey company may more easily convert capital accounts into profit reserves. The existing procedure, which involves court confirmation of the reduction of capital, remains in force for those who would prefer this route.
These changes, along with other simplifications such as the introduction for par and no par value companies to transfer amounts from a number of accounts without the need for special resolutions, improvements to the rules on mergers and demergers, improvements to the rules on prospectuses, and private companies no longer being required to hold an AGM unless they opt-in by special resolution all serve to update and simplify the Law and improve its usefulness to the international cross-border finance transactions it supports.
rejection and in principle the penalties contained in the legislation will apply.
Foreign companies are no longer required to submit their constitutional documents, only basic registered details of the company; company name and number, jurisdiction of incorporation, date of incorporation and the address of the established place of business or address of land it holds in the Island. This may make enquiries difficult for the creditor or consumer who needs further information from abroad.
A foreign company is still required to make an annual return, failure to submit within the required time represents an offence and the foreign company may be removed from the register.
Service of Process With one exception, a foreign company must ensure that it is able to accept service of process and notices in the Island. Oddly, a significant change is that a foreign company which holds land in the Isle of Man is no longer deemed to have established a place of business in the Isle of Man but is still required to register as a foreign company. In those circumstances it is required either to provide an address in the Isle of Man or by way of exception to the rule, outside of the Isle of Man for service. This change has not been reflected in the amendments to the Rules of High Court of Justice (Rules) contained in the Schedule to the Act. These provide that where a foreign company has no address for service, a document must be left at the address of the person who is authorised to accept service
under the legislation or at any place of business within the jurisdiction. This does not catch foreign companies registered by reason of holding land in the Island which according to the Act do not have a place of business and have not provided an address on the Island. A creditor would therefore have to obtain service out of jurisdiction upon the overseas address, returning the legislation to the position which prevailed before the Companies Act 1968. This seems a retrograde step for creditors or consumers where foreign companies owning land in the Island choose not to provide a local address for service.
Notification of Events The Act makes provision for the notification of certain events; such as change of address. It also requires notification of the appointment of a liquidator or receiver over assets under the laws of a jurisdiction outside the Island. Under local law, section 238 of the 1931 Act, as applied by Part X (another referential provision) requires a liquidator to register a notice of his appointment with the Department within 21 days after his appointment. There is no similar provision for notification of the appointment of a receiver appointed under Isle of Man law. Better consumer protection would be achieved if an appointment had to be notified in all cases, irrespective of the jurisdiction in control of the appointment.
Conclusion It remains to be seen whether creditor and consumer rights have been adequately protected under the new regime in pursuing the endeavour to reduce administration for foreign companies.
“It remains to be seen whether creditor and consumer rights have been adequately protected under the new regime in pursuing the endeavour to reduce administration for foreign
CONTACT
Isle of ManAndrew WebbCounselCorporate & Commercial+44 (0)1624 647 [email protected]
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“It remains to be seen whether creditor and consumer rights have been adequately protected under the new regime in pursuing the endeavour to reduce administration for foreign companies.”
The provisions of Part XI had been amended from time to time to legislate against perceived abuses by foreign companies. For example, the deeming requirement enacted by the Companies Act 1968 that the holding of land constituted the establishment of a place of business dates back to the massive residential developments of the late 1960s when details of corporate absentee landowners were required. It was also designed to ensure so far as possible that creditors had a local remedy, by requiring the name and address of a local person for service of process and notices. Plainly, in a small jurisdiction the opportunity for fly-by-night operators is considerable and Part XI went some way to monitor foreign business activity. However, Part XI was difficult to interpret and there was a clamour for its reform.
The Foreign Companies Act 2014 The Act purports to be an overhaul of Part XI; however, a number of provisions are still referential. For example, the registration of charges provisions in Part III of the Companies Act 1931 (1931 Act) still apply without any policy change. It is noteworthy that the United Kingdom equivalent legislation has abolished the requirement for foreign companies to register charges.
The Act applies to foreign companies as well as foundations and limited partnerships; indeed any entity with a separate legal personality not incorporated in the Isle of Man. There is also the
novel addition of an election, allowing a foreign entity which is not conducting business from an established place of business or holding land in the Isle of Man but which has established another nexus with the Island, to elect that the provisions of the Act apply.
The Act helpfully includes a list of circumstances of when a foreign company is not, by reason only of one or more of those circumstances applying, to be treated as carrying on business from an established place in the Island.
Oddly, these same circumstances will also permit a foreign company to claim that it has established a nexus with the Isle of Man and thereby allow it to elect to be treated as a company to which the Act applies and make an application for registration. This is counter-intuitive, the listed circumstances not being sufficient in themselves to require registration and yet sufficient to establish a right of election to register.
The expression “established place of business” which has caused so much difficulty over the years remains undefined in the Act.
Applications for Registration Applications for registration must be made within one month of the legislation applying to an entity. A foreign company which chooses to elect to register under the Act where registration is not mandatory is required to make an application within one month of that election. The nature of an election is that time will only begin to run when the applicant itself decides it should run.
The Act introduces a power allowing the Department of Economic Development (Department) to refuse to register documents. This includes where a document does not comply with the legislation or the regulations made under it. Where a document is rejected it will be treated as not submitted, this makes it critical to ensure that the application for registration and any other documents submitted are formally correct, so as not to be in default of the one month filing requirement. There is no power for the Department to make concessions for clerical errors giving rise to
NEW IOM REGIME FOR FOREIGN COMPANIESAndrew Webb
Before the Foreign Companies Act 2014 (Act) came into force on 1 July 2014, companies incorporated outside the Isle of Man carrying on business in the Island which had established a place of business in the Isle of Man, were registered under Part XI of the Companies Act 1931 (Part XI).
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Global/BermudaCameron AdderleyGlobal Group HeadCorporate & Commercial+1 441 298 [email protected]
BermudaTimothy FariesGroup Head, Bermuda+1 441 298 [email protected]
GuernseyJeremy BerchemGroup Head, Guernsey+44 (0)1481 755 [email protected]
JerseyWendy BenjaminGroup Head, Jersey+44 (0)1534 818 [email protected]
British Virgin IslandsJeffrey KirkGroup Head, British Virgin Islands+1 284393 [email protected]
Hong KongJohn MeliaGroup Head, Hong Kong+852 2905 [email protected]
London/ZurichStephen JamesGroup Head, London/Zurich+44 (0)20 7469 [email protected]
Cayman Islands Bryan HunterGroup Head, Cayman Islands+1 345 814 2052 [email protected]
Isle of ManFaye MoffettGroup Head, Isle of Man+44 (0)1624 647 [email protected]
Mauritius/SeychellesMalcolm MollerGroup Head, Mauritius/Seychelles+230 203 4301 (Mauritius)+248 429 5283 (Seychelles)[email protected]
The articles in this newsletter are for information only. They should not be acted upon and are no substitute for specific legal advice. In the event that any clarification or advice is required, please contact the editor, Wendy Benjamin ([email protected])
If you would like to receive our newsletter electronically, advise us of amendments to your details, or be removed from our database, please contact Appleby’s marketing department ([email protected])
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This publication is for general guidance only and does not constitute definitive advice © Appleby Global Group Services Limited 2014
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