Company re-domiciliation in 2024

Since 2003, Healy Consultants Group assists multi-national Clients legally migrate their entities from one jurisdiction to another, while maintaining the same multi-currency corporate bank account.

Popular jurisdictions that welcome entity re-domiciliation from other countries include i) Singapore ii) Ireland iii) Delaware and iv) the UAE.

Entity re-domiciliation or migration is similar to moving house to a new neighbourhood. Everything remains the same, except the entity has a new city centre business address in a new country.

• Economic substance requirements (ESRs)

  1. In January 2019, the European Union (EU) and OECD issued guidance requiring governments in global offshore ‘tax neutral jurisdictions’ to implement economic substance requirements (ESRs), or face risk of sanctions and reputational damage.
  2. Consequently, entities registered in these countries are legally required to either i) recruit local staff and have a physical office space to continue to be locally legally tax-exempt or ii) suffer local government penalties and corporation tax.

  1. As a result, multi-national Clients ask Healy Consultants Group to project manage the migration or re-domiciliation of their tax neutral entity to a more reputable zero tax country, while maintaining the same multi-currency corporate bank account.
  2. Alternatively, we assist multi-national Clients fulfil existing ESRs including i) supplying office premises ii) supplying local staff and iii) supplying resident directors. Engagement fees are:

     Service	How long?	Annual fee estimate
     Appoint passive, professional resident director	1 week	US$6,600
     Supply local employees	2 weeks	US$6,600
     Secure local office space	2 weeks	US$950

• Reasons to re-domicile an entity

  1. To supply more comfort to international banks. Most international banks are reluctant to onboard tax neutral companies. International banks prefer to deal with companies registered in reputable jurisdictions.
  2. To move away from tax neutral jurisdiction, minimising tax evasion scrutiny from governments including FATF and OECD.
  3. To minimise economic substance requirements, to minimise ESR and other administrative burdens.
  4. To enjoy more multi-currency corporate bank account solutions. Low quality international banks welcome entities from tax neutral jurisidictions as customers. Top tier banks welcome multi-currency corporate bank account applications from reputable entities.
  5. To avail of double tax treaty benefits; reputable low tax jurisdictions supply double tax treaty access.
  6. Improve transparency of their corporate structure. Reputable jurisdictions have an online public register of shareholders and directors, giving comfort to governments, banks, suppliers and customers.
  7. To minimise costs. Domiciliation avoids the need to wind up a company in a tax neutral jurisdiction and register a new LLC in another jurisdiction.

• How can Healy Consultants Group help you?

  1. We ascertain if you really need to migrate or re-domicile to another jurisdiction.
  2. We agree with our Client the optimum country to welcome migration.
  3. We advise the new accounting and tax considerations.
  4. We advise the new legal and compliance considerations.
  5. We communicate with the existing bank re maintaining the same multi-currency corporate bank account.
  6. We consider other factors including i) CRS reporting obligations ii) FATCA and iii) ESR and iv) double tax treaties and v) public register of shareholders and directors and vi) personal income tax return disclosures and vii) so on.
  7. We agree total engagement fees and total engagement period and sign an engagement letter.
  8. Average engagement fees approximate US$10,500.
  9. We supply our Client a detailed project plan (click link), explaining weekly steps and deliverables and timelines and milestones.
  10. Only then do we begin the re-domiciliation process.
  11. Your dedicated Client Relationship Officer supplies our Client a weekly detailed engagement status update.
  12. Following completion of the engagement, we courier to our Client the new certificate of incorporation and M&A.
  13. Our in-house Accounting and Tax Department timely accurately and completely discharges your entity legal, accounting, audit and tax obligations.

• Examples of re-domiciliation jurisdictions

  Healy Consultants Group recommends our Clients re-domicile their business to reputable low or zero tax jurisdictions including i) Singapore ii) Hong Kong iii) Cyprus iv) Bulgaria v) Ireland vi) Delaware vii) Hungary viii) Madeira ix) Moldova. The following table will help you understand potential re-domiciliation strategies:

  Re-domiciliation to this country	Corporate income tax rate	Legally tax-exempt if properly structured	Blacklisted by EU or FATF?	Timeframe to re-domicile?	Our fees to re- domicile?
  Singapore	17%	Yes	No	1 week	US$9,040
  Hong Kong	16.5%	Yes	No	1 week	US$8,910
  Cyprus	12.5%	Yes	No	2 weeks	€8,000
  Bulgaria	10%	Yes	No	2 weeks	€7,000
  Ireland	12.5%	No	No	2 weeks	€7,000
  Delaware	8.7%	Yes	No	1 week	US$5,000
  Hungary	9%	No	No	2 weeks	€8,000
  Madeira	5%	No	No	2 weeks	€10,000
  Moldova	12%	Yes	No	2 weeks	US$6,000

Conclusion

Allow Healy Consultants Group to timely accurately and completely project manage the re-domiciliation of your entity.