LABUAN
OFFSHORE IN MALAYSIA
Labuan offers a range of financial services including
offshore banking, insurance, trust business, fund management, investment
holding and investment banking. Fund management activities have been given a
boost with the recent introduction of offshore securities legislation.
LOFSA, the Labuan
Offshore Financial Services Authority, was established in 1996 as a single
regulatory agency or a one-stop agency for the offshore centre. There are 63
offshore banks, nearly 50 insurance and insurance related companies and 20
trust companies, as well as numerous legal and accounting firms.
An offshore company in Labuan can take two forms. Potential offshore
investors can either set up an offshore company or a foreign offshore company,
either by incorporating or registering their companies to participate in the
offshore activities and to enjoy the attractive tax treatment provided under
the Labuan
Offshore Business Activity Tax Act 1990. The company must also
employ the services of a trust company which is incorporated under the
Companies Act 1965 and registered under the Labuan
Trust Companies Act 1990 to discharge its statutory obligations.
DEFINITION OF OFFSHORE COMPANIES
Simply put, an offshore company is a normal limited liability structure used
legally by organisations and individuals throughout the world to trade, hold
wealth, own property, and carry on business just like any other company.
What makes an offshore company distinct
from a domestic company?
Unlike companies incorporated in an individual's or a corporation's home
country, an offshore company incorporated in an offshore centre may offer the
owner :
These features make
offshore companies ideal structures for safeguarding an individual's privacy,
protecting personal wealth, minimizing tax and maximizing a corporation's
profit.
Why do tax havens and offshore financial
centres offer low or zero tax?
The governments of many countries actively seek international investment and
trade to stimulate their own economies. The offshore industry has developed as
a result of this straightforward objective.
Many of these countries are known as tax havens. Traditionally, tax havens are
free from foreign exchange controls and have introduced specific legislation
and corporate structures, designed exclusively for international business and
foreign investment. An International Business Company, or an IBC, is the most
widely used corporate vehicle in this regard with the widest variety of
applications.
THE LABUAN OFFSHORE COMPANY
A Labuan offshore company shall only carry on business in, from or through Labuan. An offshore company may not carry on business with a resident of Malaysia except as permitted by the Offshore Banking Act 1990 and may not carry on the business of banking or insurance. A Labuan offshore company has the following characteristics
TAXATION
An offshore company may elect to pay either 3% tax on audited net profits or pay a flat rate of RM20,000 per annum which would negate the requirement to appoint an auditor and file audited financial statements.
SHAREHOLDERS
The minimum number of shareholders required is one. Details of shareholders are not available for inspection by the public. No resident of Malaysia, other than a trust company or a domestic or foreign company granted a licence may hold shares in an offshore company.
DIRECTORS
A minimum of one director, either corporate or individual is required. Directors do not have to reside in Labuan. Details do not appear on the public file.
SECRETARY
An offshore company must have at least one resident secretary who must be an officer of a licensed Labuan trust company. Additional secretaries who are not resident in Labuan may be appointed.
ANNUAL
REPORTING
An annual return must be lodged annually, not later than 30 days before the anniversary of the date of the company’s incorporation. As dealt with above a Labuan offshore company can dispense with the requirement to file annual audited accounts so long as the members of the company resolve at a general meeting not to appoint an auditor. In this case an offshore company can elect to pay a flat rate of tax of RM20,000 per annum or the same amount as an annual registration fee. If, however, the offshore company intends to take advantage of the 3% tax on audited net profits then accounts must be audited by an approved auditor and filed.
RESTRICTIONS ON
NAME AND ACTIVITY
Offshore companies are allowed to have names in a foreign language, provided they use Roman characters and the letter L as part of its name.
LOCAL
REQUIREMENTS
An offshore
company must maintain a registered office, resident secretary and where
applicable must maintain accounting records in Labuan.
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GENERAL |
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Type of Company |
Offshore Trading |
Offshore Non Trading |
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Political Stability |
Good
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Common or Civil Law |
Common |
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Disclosure of Beneficial Owner
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No
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Migration of Domicile Permitted
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Yes |
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Tax on Offshore Profits
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3% on profit or RM20,000 |
Nil |
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CORPORATE REQUIREMENTS |
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Minimum Number of Shareholders |
One |
One |
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Minimum Number of directors |
One |
One |
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Bearer Shares Allowed |
No |
No |
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Corporate Directors Permitted |
Yes |
Yes |
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Company Secretary Required |
Yes |
Yes |
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Standard Authorized Share Capital |
US$ 10,000 |
US$ 10,000 |
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LOCAL REQUIREMENTS |
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Registered Office / Agent |
Yes |
Yes |
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Company Secretary |
Yes |
Yes |
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Local Directors |
No |
No |
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Local Meetings |
No |
No |
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Government Register of Directors |
Yes (not public) |
Yes (not public) |
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Government Register of Shareholders |
Yes (not public) |
Yes (not public) |
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ANNUAL REQUIREMENTS |
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Annual Return |
Yes |
Yes |
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RECURRING GOVERNMENT COSTS |
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Minimum Annual Tax / License Fee |
RM 2,000 |
RM 2,000 |
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Annual Return Filing Fee |
RM 100 |
RM 100 |
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Protect Wealth. Save Tax. Reduce
Operating Costs.
Individuals and corporations go offshore for a number of reasons:
Use the information
and links set out below to help you find an offshore solution that works for
you.
» International
trading
» Holding
portfolios of stocks, bonds and cash
» Holding
Investments in Subsidiary or Associated Companies
» Utilising
Double Taxation Treaties
» Privacy
and Wealth Protection
» Personal
Service Companies for expatriates and individuals
» Property
and Land Ownership
» Employment
Companies
» Patent,
Royalty and Copyright Holding
» Stock
Market Listings and Capital Raising Exercises
» Financing
» Ship
Management + Yacht Owning
International Trading - By
interposing offshore companies into international trading transactions it may
be possible to accumulate profits arising out of these transactions.
Holding portfolios of Stocks, Bonds and
Cash - Cash assets are held offshore, and may earn deposit
interest gross or be placed in collective cash funds.
Holding Investments in Subsidiary or
Associated Companies - Capital gains arising from the disposal of
particular investments can be made without taxation. In the case of dividend
payments, reduced levels of withholding taxes can be achieved through the use
of a company incorporated in a zero or low tax jurisdiction that has double tax
agreements with the contracting state.
Utilising Double Taxation Treaties
through Intermediary Holding Companies. Companies wishing to invest in
countries where a double tax agreement does not exist between both countries
can establish an intermediary company in a jurisdiction where there is a
suitable treaty.
Privacy and Wealth Protection -
High net worth individuals gain privacy and save on professional fees by using
offshore companies as Personal Holding Companies. These entities may be
suitable for inheritance planning and reducing the costs and time delays in
probate.
Personal Service Companies -
Individuals who provide professional services, such as contractors,
entertainers, aviators, film executives etc., can realise considerable savings
where fees earned are accumulated tax free in Personal Service Companies based
offshore. Payments may also be structured to minimise income tax.
Property and Land Ownership -
Offshore entities are regularly utilized to own property and real estate.
Employment Companies -
Payroll costs and travel expenses may be reduced by paying employees working
overseas from your offshore base. This may also provide tax relief and social
security saving benefits for the employees.
Patent, Royalty + Copyright Holding -
Intellectual property including computer software, technical knowledge,
patents, trademarks and copyrights, can be owned by, or assigned to, an
offshore company upon acquisition of the rights. The rights can then be
franchised to companies around the world and the resultant income can be
accumulated offshore. A carefully selected jurisdiction can withhold taxes on
royalty payments with the commercial application of double tax treaties.
Financing - Offshore
companies can be established to fulfil an inter-group treasury management
function.
Ship Management + Yacht Ownership -
Modern ship and pleasure craft registration locations provide low-cost
registration fees and tax exemption income derived from shipping and chartering
activities.
Stock Market Listings and Capital Raising
Exercises - Many large corporations in economically and
politically uncertain countries often diminish the perception of risk by moving
ownership of assets and the base of their operations offshore.