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Newsletter | Articles Seychelles conference looks at China DTA SIBA – the Seychelles International Business Authority - organised a round table session in partnership with the Asia Pacific Offshore Institute at its Offshore 2003 conference in Hong Kong. The Conference attracted more than 100 participants worldwide and the Seychelles was strongly represented. The round table session was designed to inform delegates of the procedures and benefits associated with the use of recently enacted Companies (Special Licenses), Protected Cell Companies and the Limited Partnership legislation. The emphasis was on the low tax Special License Company, a tax resident company which enjoys access to Seychelles network of Double Taxation Agreements (DTAs). The session was chaired by a local offshore practitioner and the main speaker was Dr. Willem Kuiper, a specialist in tax planning. The round table session examined how the specified activities licensed under the Companies (Special Licenses) Act can be used to reduce tax liabilities. Examples were given using investment management and advice companies, offshore banking, offshore insurance, reinsurance etc… In particular, the Seychelles has a very attractive DTA with China, with a maximum withholding tax of 5% on dividends. Hong Kong delegates had a particular interest as it would allow them to structure investments through the Seychelles to take advantage of the tax savings compared to other jurisdictions offering similar company structures. The round table session also focused on how a Special License Company can be used for investments from China to South Africa. It was illustrated that if gross dividends of US$100 are taxed in China at 15%, the dividend that remains is US$85. That dividend is then taxed at 1.5% in Seychelles and the Special License Company thereafter receives a tax residency certificate from the Seychelles as that company has paid taxes on income. This certificate will entitle the Special License Company to a tax credit equivalent to the tax paid by a Seychelles domestic company. Seychelles companies are available from all ILS offices.