Contesto 10:54 Apr 28, 2008
The use of terms "coduit and base" is rather technical. The conduit compay focuses upon minimization of source country withholding taxes on investment income so it is located in a country with relevant tax treaties which also exempts or puts a low tx on receipts of passive investment income ... ... The base company is formed in a classical haven, whose low/no tax regime allws it to carry out a number of functions on behalf of the group, reducing liabilities of affiliates of high-tax countries, while profits channeled to the base company are subject only to the no/low tax regime. |