Cititrust International Ltd. The Cititrust Quarterly Review

Volume 1, Issue 1 January—March, 2009 Points of Interest: • BOPA Maps the Direction for Belize’s International Financial Services: Is the Offshore Sector Industry to Blame for the Global • China Economic Crisis? Implements New Income Tax Rules As the effects of the version of the Bill had transactions, Baucus been co-sponsored by Bill diverges from • G20 Summit global economic downturn continue to then-Senator Barrack STHAA in its approach and the “New to compiling a list of Black List” take its toll on international financial secrecy jurisdictions, a • International stability, jurisdictions “Blacklist”. Baucus Bill Financial that provide international supporters argue that the Services : financial services have Bill is less punitive than Financial come under increasing STHAA in several Revolution of scrutiny. respects. Most notably, it New avoids the compilation of Millennium? Critics of the offshore a blacklist, yet advocates sector argue that ‘tax United States Capitol Building strong measures to havens’ exacerbate the combat financial crisis by Obama. In a similar including providing the undermining the tax move, Sen. Max Baucus IRS with additional Inside systems of the countries (D-MI) introduced a draft powers to detect and this issue: whose residents utilize bill for circulation, deter offshore abuses. such vehicles. On March commonly referred to as While it is unclear which IFS: Cause of the 3, 2009, Sen. Carl Levin Baucus Bill. While the Bill, if either, will be Global Financial 1 (D-MI) re-introduced a latter contains similar passed into US Law, Crisis? revamped version of his provisions to STHAA financial practitioners 2007 Stop including extending the worldwide continue to Chinese CFC 1 Abuse Act (STHAA) to statute of limitations on warily monitor the Rules the US Senate and assessment from 3 years situation. While the Congress; the 2007 to 6 years for certain United States Whence the “Brass Plate” 4 and “Banking Secrecy” Chinese CFC Rules and Outbound Investment

BOPA Looks to based" approach, the entire detailed workings of these the Future of The People's Republic of 6 law contains only 60 rules are going to emerge Belize’s Offshore China on December 11 articles, meaning that over the next few Sector issued the implementation rules for China's new implementation rules, months. China has already Enterprise Income Tax future circulars, and other issued a list of countries to (EIT) Law. The new law, guidance will outline the which the CFC rules do not IFS: Financial enacted on March 16, took specific impact on apply to entities resident in Revolution of 9 effect on January 1, 2008. taxpayers. China due to the fact the 21st Century Under China's "principles- The regulations and that their effective tax Page 2 Offshore Financial Services: Is the Industry to Blame for the Global Economic Crisis? Cont’d.

spearheaded the charge substantially nor Macau made neither to force “secrecy implemented the of the three revised jurisdictions” to reveal internationally agreed tax OECD lists. the identities of high net standard”. Barbados worth clients and major made this list. Thirty- Still all is not lost for corporations who have eight countries were Caribbean low-tax utilized their services, designated to the “grey jurisdictions, especially they have also garnered list” - jurisdictions that as the Fifth Summit of G20 Leaders the support of other have committed to the the Americas approaches. The Summit, which is gather at major OECD and G20 internationally agreed tax countries. In Europe, being hosted in Trinidad London standard, but have not Germany and France yet substantially and Tobago from April Summit on have been instrumental implemented them. 17th — 19th, will bring April 2, 2009 in the fight to restrict Included in this list were together Heads of State several CARICOM and and Government from other Caribbean throughout the Western jurisdictions — Anguilla, Hemisphere, including Antigua and Barbuda, President Barrack Obama Aruba, Bahamas, Belize, of the United States, and Bermuda, British Virgin President Hugo Chavez Islands, Cayman Islands, of Venezuela, marking “With regard to Dominica, Grenada, the first meeting where the list of financial secrecy and Netherland Antilles, St. both these Heads of State will be present. It is jurisdictions curtail the activities of Kitts and Nevis, St. Lucia, expected that the top that have not “tax havens”. St. Vincent and the Grenadines, and Turks issue on the agenda will committed to Building on the and Caicos Islands. be the global economic momentum of the G20 the Finally, with regard to crisis — such discussion pledge to crack down on internationally the list of jurisdictions will most likely feature tax havens and bring an agreed tax that have not committed deliberations concerning end to banking secrecy to the internationally the ‘crackdown’ on standard - four laws, the OECD released agreed tax standard — offshore jurisdictions. countries were a revised version of its the notorious “Blacklist” deemed non- infamous “Blacklist”. — four countries were cooperative” Forty countries were deemed non-cooperative: given a clean bill of Costa Rica, Malaysia health, falling under the (Labuan), Philippines, classification and Uruguay. “jurisdictions that have Interestingly, Hong Kong

Chinese CFC Rules and Outbound Investment cont’d

rates are greater than 12.5%. The State that are higher than the threshold Administration of Taxation (SAT referred to in the controlled foreign issued a ruling (Guo Shui Han [2009] company CFC rules of the Enterprise No.37) on January 21st, 2009 stating Income Tax Law. that India, UK, Australia, USA, Norway, South Africa, Canada, Chinese CFC rules will have a major France, Germany. Italy, Japan, and impact on outbound Chinese New Zealand have effective tax rates Investment structuring. As a result

The Cititrust Quarterly Review Volume 1, Issue 1 Page 3 Chinese CFC Rules and Outbound Investment cont’d

network and the scope for will have an extremely low cost effective substantial “cost of substance”. This is operations that could be an opportunity Belize could implemented. easily grasp because, as other countries are demonstrating, Indubitably, Chinese tax rules new Tax Information are quickly taking the same Exchange agreements can be thrust as US and UK tax CFC concluded in a matter of “Chinese rules. It won't be more than weeks. tax rules two years before Chinese are quickly outbound investment requires This is another a reason why we of the new Chinese CFC rules the a similarly sophisticated level of believe Barbados can be a taking the undistributed or under international tax planning. successful proposition in China. same distributed profits arising from Clearly the use of offshore There are major opportunities CFCs of the above listed countries thrust as companies by Chinese for a country like to Belize to US and UK do not need to be included in the residents will be declining over quickly reposition itself within taxable income of the Chinese the short term as these rules the envelope and actually tax CFC resident shareholder provided take effect. become extremely competitive. rules. that a resident shareholder can We will continue to monitor the produce the evidence of his or her As the OECD information Chinese State Administration of residency. Chinese shareholders sharing standard is rolled out Taxation and the Guoshuifa of CFCs in other countries across the low tax jurisdictions (circulars) issued by them. especially in low tax jurisdictions including Singapore, Switzerland will be charged on their income etc and loopholes such as those on an arising basis, or in the EU Savings directive are immediately, as profits accrue. closed, the playing field will become more level and Notably the CFC rules may international tax planning be deemed not to apply, and experts will become more may be avoided by Chinese attentive to the cost of residents, if the CFC has substance. Countries like sufficient substance and Ireland and Cyprus will be able commercial purpose. The to deliver low tax solutions but meaning of substance and will be competitively pressured commercial purpose requires from a “cost of substance” further elucidation. perspective. This is a clear opportunity for Barbados to This is an opportunity for the leverage its low tax solution Barbados model in that with a comparatively “low cost Barbados resident entities of substance” advantage. and family offices and financial institutions with Other low tax jurisdictions like sufficient substance using the Belize and Seychelles are likely Barbados treaty network will to have to enter this space of be attractive to Chinese enabling low tax through residents. Given that substance. Information Barbados treaty network Sharing to OECD standard with extends to Latin America, the TIEAs and Art 26 on tax USA and Europe, all of these treaties will in 2009 remove the markets can be accessed and usefulness of offshore profits cost effectively companies to Chinese resident accrued in Barbados. Of the shareholders as an outbound many low tax jurisdictions, investment structure. The Barbados is one of the few main advantage that countries jurisdictions with a treaty like Belize will have is that they Chinese Parliament, Beijing, China

The Cititrust Quarterly Review Volume 1, Issue 1 Page 4 Whence the “Brass Plate” and “Banking Secrecy”

The “perfect storm” has come information exchange will

UBS, A and the main they seek to do it via double Leading players have tax treaties or will they use Swiss Bank taken action. only Tax Information specializing in wealth Exchange Agreements. Truly management, Clearly the the number of double tax and ending of treaties worldwide is set to international banking banking increase at an even faster secrecy is not rate. Some jurisdictions like going to be an immediate Cayman and BVI with their The “Era of Banking one. Countries like established fund sectors are Secrecy is over”. Is this true Switzerland who have likely not to need DTAs and and what does it mean? contacted 48 of their treaty can settle for TIEAs “April 3rd partners and signalled saw the Out of the 2ND April 09 readiness to negotiate will Now that secrecy is no longer OECD London G20 Summit, the take some time before they a viable long term tax issue a G20 communiqué officially are able to complete these planning tool also with it outlined action regarding tax negotiations. Singapore has goes the brass plate company blacklist havens and information 52 tax treaties. This is going as the “clever” part of a indicating exchange. April 3rd saw the to be the case across the simple cross border countries OECD issue a blacklist entire list of countries who structure. Clients are going that had indicating countries that had have been flagged as having to have to implement cost taken taken action and those that committed to the TIEAs effective but transparent and action and had not. standard but have not yet substantial international tax those that implemented sufficient structures if they are to had not.” It is quite important to note agreements to be said to be achieve long term tax that what developing in compliance. Therefore, it efficiency. The real prospects countries are seeking is tax is most likely that secrecy lie in exploiting the information exchange will decline gradually over opportunities in real according to the article 26 of the next two years. commercial activity rather the OECD model. Many than the clever but commentators have made Those individuals however that point that pursuit of tax who are sufficiently havens is a red herring but sophisticated will this week they failed to realise that for instruct their advisors to revenue hungry debt laden move them to something western governments, Tax which is long term compliant Information exchange was with the evolving situation always the low hanging fruit. thereby avoiding the complexities of tax evasion. With the onset of the Still others will have to recession, countries like the receive that letter from the USA and UK are bailing out HMRC before they realise their banks to the tune of what is happening and have trillions and they are set to to contact their advisors or run deficits for some time to appoint some. come. Why would they not increase the revenue What is interesting is that collection by targeting now that all the small tax unsophisticated tax evasion. havens have to implement Swiss National Bank

The Cititrust Quarterly Review Volume 1, Issue 1 Page 5

Whence the “Brass Plate” and “Banking Secrecy” cont’d artificial “schemes” and are issued for Family offices as an International Financial structures of the past. Tax and Private Equity funds of Centre. authorities worldwide are which there are over 60 striking down artificial operating in the country. Belize has a West Minister structures at speed while Barbados has a treaty style constitution and its introducing demand for network with eighteen legal system is based on the substantive tax planning. countries and counting and English common law system. China has implemented Unlike most Caribbean Transfer Pricing, Thin Cap, nations, Belize has over 8000 CFC and GAAR in 2009 square miles; both English alone. The UK has revamped and Spanish spoken. As its CFC rules and has now private clients, individuals setup a special unit to review and SMEs begin looking for “Barbados the tax affairs of the 5000 cost effective substantial may have a richest people in Britain. The international tax structures bit of a leap USA is working on the Stop that can deliver tax benefits, on other low Tax Haven Abuse Act half of places like Belize with its tax centers which codifies the economic miles and miles of beaches seeking to build treaty substance doctrine of the US Flag and Parliamentary and islands off of the cost will networks courts. Whereby Building of Barbados be much more cost effective given that multinational corporations and pleasant than say Ireland the US is not have become accustomed to only some of the treaties or Luxembourg. Also closer likely to sign this type of tax planning, have carved out provisions. for Americans than say or negotiate such structures are likely to Barbados may have a bit of Bermuda or Lichtenstein. a double tax become the only option for leap on other low tax centres Smaller countries like Turks treaty with a private clients and those building treaty networks and Caicos, Cayman and BVI low tax engaging in cross border because the USA is not likely would not be able to compete jurisdiction business unless they just to sign or negotiate a double on a marginal cost basis with for some want to ensure that they pay with a low tax a country like Belize in the time.” what they are due to pay and jurisdictions for some time. future. no more. Ireland, Cyprus, Malta, and the Netherlands Belize has been classified as As the Obama administration are some of the countries and having agreed to the lets loose the civil servants of jurisdictions that come to principle of tax information the IRS upon unsuspecting mind when one contemplates exchange but has not yet US citizens, already they are the options that small implemented it. The country passing a plethora of countries can take. has three double tax treaties, regulations and changes namely with the UK, Barbados was the smallest CARICOM and Austria. The country to obtain a clean bill country’s territorial tax of health from the OECD. system is similar to Hong What is interesting is that Kong and Singapore. In this Barbados has a ring fenced current climate, Belize has regime which is unique in the everything to play for. If the world due to the fact that an Belizean authorities can audit and accounts are negotiate DTAs with their required after US$500K neighbours like Canada, revenue. Barbados has an USA, Mexico, Costa Rica and International Financial some of their Latin American Service Act under which neighbours they could Flag of Belize; Prime Minister of Belize, restricted banking licenses actually compete worldwide Hon Dean Barrow

The Cititrust Quarterly Review Volume 1, Issue 1 Page 6

Whence the “Brass Plate” and “Banking Secrecy” cont’d

behaviour in US HNWIs and SMEs.

“Smaller countries like Turks and Caicos, Cayman, and BVI would not be able to compete on Dock in Stann Creek District Belize, C.A. a marginal that are going to seriously attack US citizens cost basis simplistic use of offshore jurisdictions. The with a planned changes for the Qualified Intermediary country regime and the cases against UBS offshore like Belize account clients not to mention the Stop Tax in the Haven Abuse Act which has not yet been passed future.” but is likely to. American citizens will also have to become more sophisticated in their approach to international tax planning and opportunities of reducing taxes on their international income. Belize could well be a big player in that change of Map of Belize

BOPA Makes Recommendations for the Future of Belize’s International Finance Sector

With assets approaching Belize opened a significant capital ensure its sustainability going source for key Belizean forward. US$400mn, and deposits industries, for example — citrus. exceeding US$280mn, the Belize’s comparative advantage significance of Belize’s international as an ‘offshore jurisdiction’ has finance services industry to the historically been predicated

country’s economy cannot be upon its cost effectiveness, the overstated. Since its inception in flexibility of the laws governing the early 1990’s, the industry’s the industry, and most contribution to employment, not importantly, confidentiality. to mention hard currency The absence of tax information earnings, has served as a buffer exchange agreements (TIEAs) against various economic has meant that Belizean downturns. Meanwhile, a 2002 authorities are not compelled to Amendment to the International reveal the beneficial owners of Banking Act which provided for Against this background, the those who utilize Belize’s domestic companies with Belize Offshore Practitioners investment vehicles, provided Economic Processing Zone (EPZ) Association (BOPA) has there has been no serious and Commercial Free Zone (CFZ) intensified its efforts to enhance infraction of the Anti-Money status to conduct business with awareness of Belize’s International Laundering/Combating the international banks licensed in Finance Sector, and the need to Financing of Terrorism

The Cititrust Quarterly Review Volume 1, Issue 1 Page 7

BOPA Makes Recommendations for Belize’s Offshore Sector cont’d

regimes. Notwithstanding a prudent to focus on with the following Module 2 Offshore Financial confidentiality as the jurisdictions—Mexico, Center Assessment distinguishing feature of the Canada, and the United conducted by the IMF in Belize investment product, States of America, and August 2003 which especially if the country is to such other jurisdictions concluded that Belize had demonstrate its commitment that may be prudent, made “significant progress to restricting the use of its provided that there is a de toward compliance with investment vehicles for tax minimis and savings and/ many of the FATF evasion or other unlawful or transition period set out Recommendations and Special purposes. therein. In return, Belize Eight Recommendations on should at no time be Terrorist Financing”, the regarded as a ‘tax haven’ or OECD recently placed Belize otherwise adversely on its ‘grey list’, along with blacklisted by such various other Caribbean low- jurisdictions, or any tax jurisdictions. The main multilateral organization reason cited by the OECD for of which they are a the ‘grey list’ categorization is member. that while these jurisdictions “No longer is it 5. Establish a clear definition have committed to the prudent to focus as to what constitutes ‘tax on internationally agreed tax In its letter to the Prime fraud’ under Belize law confidentiality standards, they have not yet as the main Minister, BOPA recommended that is consistent with substantially implemented advantage of the the following (paraphrased for what constitutes ‘tax fraud’ them. Given the current Belize the purpose of this article): under US law. investment global recession, one cannot Furthermore, ‘tax fraud’ product” help but question whether or 1. The Government of Belize should be established as a not offshore financial centers should enhance its serious crime for the have become the convenient lobbying efforts purpose of the newly scapegoats for developed unilaterally and with other enacted Money Laundering countries seeking to recover CARICOM jurisdictions, and Terrorism Prevention much needed income. Even especially at the upcoming Act, and any treaty into so, heightened scrutiny on Summit of the Americas, which Belize might enter. jurisdictions like Belize in an effort to keep Belize continue to fuel anxiety from being listed as an 6. Rather than promoting about the sustainability of “offshore secrecy confidentiality, Belize the country’s emergent IFS jurisdiction” for the should strengthen its industry. purpose of the proposed asset protection laws and STHAA. promote protection as In light of these the primary attraction of developments, BOPA has 2. Ascertain definitively the Belize investment mapped a possible way conditions that Belize must vehicles . forward for the industry. meet to avoid further BOPA then forwarded its harmful listings. While these are merely proposal to the Prime recommendations, BOPA’s 3. Implement necessary Minister of Belize, Hon. Dean Executive and its measures to avoid such Barrow. The crux of BOPA’s membership endorse these listings. recommendations is to measures as the best way to modify the way Belize 4. Enter into most favored ensure the survival and markets its investment nation Avoidance of success of Belize’s IFS vehicles. No longer is it Double Taxation Treaties industry. In his response,

The Cititrust Quarterly Review Volume 1, Issue 1 Page 8 BOPA Makes Recommendations for Belize’s Offshore Future cont’d the Prime Minister, Hon. Dean efforts to mitigate any further fall- revamping Belize’s Barrow, reiterated the concerns of out for Belize. The Prime Minister legislation to ensure the BOPA with regard to the ‘crackdown’ also assured BOPA’s Executive that survival of this vital on offshore jurisdictions by developed he would give careful consideration industry. countries, and expressed his to the recommendations that had commitment to pursuing lobbying been tabled with a view to

Barbados and Mexico Double Tax Treaty

Mexico's tax treaty network is international financial service property are not taxed in Mexico. comprised of 37 treaties with vehicles. Barbados international The taxing rights for Capital Barbados being one of the latest entities such as the International Gains from “other property” are additions. It has been in force since Business Company and the Society allocated to Barbados. As 2008 but the provisions will take full with Restricted Liability cannot mentioned above Barbados does effect on Jan 1st, 2010. benefit from the dividends, interest, not have capital gains tax. realties, capital gains nor Additionally, the Barbados — From the 37 countries with which independent services articles. Mexico treaty provides that Mexico has a tax treaty in force, 22 capital gains derived from the have a broad exchange of Under the Barbados International sale of shares where the information agreement as well. Financial Services model however shareholding of the alienator is Barbados is one of these with article the Barbados international entities greater than 25% then those 27 implementing the full standard of can access the PE and Business gains are taxable in México. Of the OECD model for Exchange of profits and other articles of the course this means that where the Information. Barbados Mexico DTA. For example shareholding of the Barbados a Barbados IBC with an International company is less than 25% the Barbados was included on the first Banking License under the capital gains taxing rights will be issue of the white list of countries in International Financial Services Act allocated to Barbados. full compliance with the OECD would be able to access the PE and standard of information sharing. business profits and other articles of Whether it is a Mexican Barbados is an excellent jurisdiction the DTA. A Mexican resident could corporation making cross border for implementing international therefore use such a low tax treaty investments in USA, Canada, based structure to facilitate outward structures with commercial Europe or China the Barbados investment. Barbados’ IBCs have full substance. Commercial substance is double tax treaty network offers the new emerging access to the benefits under the Barbados China DTA. In a similar some valuable options well worth standard. China has recently considering. Also inbound introduced a requirement of fashion the Barbados IBC with a Mexican investors will have “business purpose” under its new banking license is not entirely options where there is Private Enterprise Income Tax law (EIT). excluded from the provisions of the There is a ten year retrospective Barbados USA double tax treaty. Equity of wealthy individuals aspect to this requirement for making larger investments. Now business substance under the new Taxation of Capital Gains that Barbados has a treaty with EIT law. The United States also in Barbados does not tax capital gains. Mexico, Mexican residents do A Barbados domestic company the Stop Tax Haven Abuse Bill, half not need to report the holding or owning intellectual of which is dedicated to the establishment of Barbados codification of the economic property in Mexico can sell that intellectual property and realise that structures to the Mexican tax substance doctrine of the US tax authorities. Barbados should jurisprudence. gains in Barbados as the taxing rights have been removed from that list under the treaty have been allocated once the treaty came into force. The Barbados — Mexico treaty has to Barbados. In Mexico under the major implications for Barbadian CGT regime capital gains are taxed entities, especially considering that under the Mexican Income Tax rates. The way is essentially now open Mexican CFC rules would no longer This is all possible because the for these new opportunities to be Mexico Barbados treaty says that the apply to them. The treaty does carve explored. out provisions for Barbados gains arising from the sale of “other”

The Cititrust Quarterly Review Volume 1, Issue 1 Page 9 A Word from the Editor International Financial Services: The Financial Revolution of the 21st Century?

Financial Centers (OFCs) Update few jurisdictions that consistently posted October 2008, the Fund demonstrate high levels of underlined the need to improve regulatory integrity, and most understanding of the activities of OFCs, importantly, political and and their linkages to the global financial economic stability. system. To date, the IMF has conducted Offshore Financial Center Gloria Garcia, Assessments in Andorra, Anguilla, Belize — The Preferred IFS Editor, Aruba, The Bahamas, Belize, Bermuda, Center Cititrust Quarterly Review British Virgin Islands, Cayman Islands, [email protected] Cook Islands, Cyprus, Gibraltar, Belize, a British colony until Guernsey, Isle of Man, Jersey, September 21st 1981 when the The face of global finance Liechtenstein, Macao, Malaysia, country gained independence, has evolved significantly Monaco, Montserrat, Netherlands enacted its international sector from its banking origins with Antilles, Republic of Palau, Panama, with the passing of a series of the advent of more complex Samoa, Seychelles, Turks and Caicos offshore legislation. The and sophisticated financial Islands, and Vanuatu. All these Merchant Ships Act, which set up institutions offering a wide assessments have been voluntary and a registry for the registration of range of financial services, conducted with a vision to enhancing vessels flying the flag of Belize, typically transcending geographical cooperation amongst supervisors. was passed in 1989. In 1990, borders. Against this Belize passed its IBC Act, background, the growth of the While the growth in jurisdictions legislating the establishment of international financial services offering international financial services the Belize IBC whose features sector exploded with a has been relatively momentous in the have grown to include an efficient commensurate increase in the recent decade, international investment registry that conducts number of jurisdictions offering vehicles have been around for some incorporations typically within 24 services ranging from time now; The British Virgin Islands hours of receipt of payment and international banking to investing. (BVI) introduced its International all constitutive documents. The Notwithstanding this phenomenal Business Companies (IBC) Act in 1984. Offshore Banking Act, subsequently growth, the sector has suffered Panama also served as a pioneer in the revised and renamed the some disrepute and notoriety as industry. International Banking Act, was numerous controversies continue International Business Companies, passed in 1996; the Central Bank of to tarnish its image. Despite these Limited Liability Companies, Trusts, Belize regulates and supervises all challenges, international financial etc. have become embedded additions international banks. Meanwhile, services continue to solidify their to the new economic and business the passing of the Trust Act in 1992 position as innovative financial models, with individuals and firms and the International Insurance tools with immense potential for alike routinely capitalizing on the Act in 1999 solidified Belize’s growth. To this end, there has advantages of such investment vehicles. arrival as a premier financial been a proliferation in jurisdiction The main benefits of these structures jurisdiction. offering such services, including include tax planning, simplicity, legal the United States and Japan and protection, limited reporting other major members of the requirements, asset protection, minimal Organization for Economic Co- capitalization requirements, and some operation and Development degree of anonymity (although recent (OECD). developments threaten to erode this The International Monetary Fund feature). (IMF) lists as many as sixty active Despite the wide availability of jurisdictions that offer offshore centers, most investors and international financial services. their professional representatives In an Assessment of Offshore prudently gravitate toward a select Central Bank of Belize

The Cititrust Quarterly Review Cititrust International Ltd.

35 Barrack Road, 3rd Floor, Suite 301 Belize City, Belize Central America

Phone: 501-22-33738, 33896 Fax: 501-22-33501 E-mail: [email protected]

Protecting and Building Your Assets is Our Business

Cititrust International Limited, having commenced operations over a decade ago, is the largest international financial services provider in the emergent financial jurisdiction of Belize. The company’s unparalleled abil- ity to attract and combine the expertise of highly qualified, experienced, and proficient tax professionals, fi- nancial experts, and legal practitioners has earned Cititrust a reputation for integrity, professionalism, and efficiency. Apart from the Belize IBC, Cititrust International offers Trusts, Mutual Funds, Annuities, Tax- Deferred Variable Annuities, Limited Liability Partnerships Formations, Nevis Limited Liability Company Formations, Mutual Fund License procurement and Set-Up, and Hybrid Company Formations. In conjunc- tion with our affiliates – Glenn D. Godfrey and Company LLP, a prestigious Belizean international law firm; Provident Bank and Trust International, one of Belize’s leading international banks; Paragon International, and Corporate Impressions, Cititrust clients benefit from unrivaled accessibility to comprehensive financial products and services. Notwithstanding, the costs of Cititrust products and services remain highly competi- tive, even when compared to practitioners from “low-cost jurisdictions”. In addition to headquarters in Be- lize, Cititrust offices in Barbados, Seychelles, and Hong Kong also provide regional and global support to our worldwide clientele.

www.cititrust.biz

The Cititrust Quarterly Review