Taxation of Isle of Man Companies from April 2006

At the present time a company incorporated incompany and 100% for an investment company
the Isle of Man, owned by non-residents andoro A company owned wholly by non- residents,
which complies with the other statutoryregardless of what percentage of profit is actually
requirements, is not liable to Isle of Man taxation.distributed.
Whilst locally trading companies pay tax at 18%, aIt is this third category of qualification, which is
qualifying offshore company pays a flat annualthe most important, as it means that companies,
tax of £475 or £1,000.incorporated on the Isle of Man but wholly owned
The Isle of Man is however required to complyby non-residents, will continue to enjoy tax- free
with the E.U. Code of Conduct on Businessstatus.
Taxation and other international initiatives designedCompanies will have to apply for distributing
to eliminate discrimination between taxpayers. Thisstatus but the exact means by which they will do
means, essentially, that the tax treatment of localso has not as yet been decided. The Government
and offshore companies should be the same. Thehas however indicated that companies which have
Island decided some time ago that it would meetsuccessfully claimed such status may not be
its obligations by introducing a zero rate ofrequired to submit accounts with every tax
taxation for all companies except those engagedreturn providing sufficient information is provided
in certain finance sector activities and theon the return to support the claim.
Government has now issued a consultation paperThere are further rules which apply to companies
outlining how it is proposed that the new systemwhich are wholly or partly owned by Isle of Man
will operate.residents and these companies will be obliged to
From April 2006 the distinction between offshorecalculate the tax payable on that part of the
and locally resident companies will disappear andprofits applicable to local shareholders and to pay
companies will be classified as distributing orit over to the Treasury.
non-distributing. A distributing company will be oneThe new system will accord with the international
of the following,o Where the whole of theobligation for the Isle of Man not to discriminate
distributable profit has been charged to tax at thebetween onshore and offshore companies and
rate of 10% oro Where the company hasenable it to escape the sanctions, which may be
distributed a specified minimum of its distributableinvoked against some of the other offshore
profit, expected to be 60% for a tradingcentres.