Country guide to tax on Quilter International bonds · 4 Country guide to tax on Quilter International bonds Quilter International India (2017) QIntl Ireland dac and QIntl Isle of

Country guide to tax on Quilter International bonds

For adviser use only

This guide is to help you advise individual local or expat policyholders who have invested into either a Quilter International Ireland dac (‘QIntl Ireland dac’) or Quilter International Isle of Man Limited (‘QIntl Isle of Man’) life assurance or capital redemption bond and who are planning to move to the countries listed below. It gives a summary of the tax position in each case.For ease of reference, we have used a red, amber, green rating system to indicate how favourable the tax position is in that country. Where a bond type has not been listed under a country this is because we have not obtained local tax advice for it. The year stated in brackets in the ‘Country’ column is the year we obtained the legal advice of the country referenced, or the year we have verified this information, to be correct.

Country guide to tax on Quilter International bonds2 Quilter International

Key = Most favourable = Moderately favourable = Least favourable

CGT = Capital Gains Tax IHT = Inheritance Tax QIntl Ireland dac = Quilter International Ireland dac QIntl Isle of Man = Quilter International Isle of Man

Countries covered in this guideThis guide can help you advise clients who are moving to the countries highlighted on the map below


Country client is moving to

Type of offshore bond High level tax position Further information

Australia (2018) QIntl Ireland dac and QIntl Isle of Man - Life bond

– Gross roll up. – Income tax is payable on gains arising on surrenders in the first ten policy years from commencement. – The ten years restart if a top up premium exceeds 125% of the premium paid in the previous policy year. – The death benefit is not taxable. – There is no inheritance tax and wealth tax in Australia. Full details of the products from Quilter

International are available on our website.

‘Internationally mobile solutions’ sits in the Technical Centre (adviser part) of our website and provides useful information on Australia.

QIntl Ireland dac and QIntl Isle of Man - Redemption bond

– Income tax and capital gains tax are payable on gains arising on surrenders in the first ten policy years from commencement.

– Gains arising on surrenders after ten policy years are only liable to capital gains tax. – Anti-overlap provisions reduce the double tax charge during the first ten policy years. – The ten years restart if a top up premium exceeds 125% of the premium paid in the previous policy year. – There is no inheritance tax and wealth tax in Australia.

China (2019) QIntl Isle of Man - Life bond

– Gross roll up. – Gains arising on surrender and death are not taxable in China. – There is no inheritance tax or gift tax in China. – There is no wealth tax in China.

Full details of the products from Quilter International are available on our website.

‘Internationally mobile solutions’ sits in the Technical Centre (adviser part) of our website and provides useful information on China.

France (2019) QIntl Ireland dac - Life bond

– Gross roll up. – Gains arising on surrenders are liable to income tax and social security taxes. – Death benefit payments are subject to specific Assurance Vie inheritance tax rates. – The gain arising on payment of the death benefit is liable to social security taxes.

Premiums paid from 27 September 2017 – Policyholders can elect to be taxed on chargeable gains using the ‘Prelevement Forfaitaire Unique’ (PFU) rates,

known as the ‘Flat Tax’, or at their marginal income tax rates. – The PFU rate payable during the first 8 years is 12.8%. After the first 8 years, the rates are 7.5% and 12.8% on

the proportionate amount of gain below and above the threshold. – The threshold of €150,000 refers to the amount of premium remaining in all the Assurance Vie policies owned

by the policyholder. – Social security tax of 17.2% is payable in addition to the PFU rates above.


The Vive la trusts ‘Knowledge Direct’ article also provides useful information.

QIntl Isle of Man - Life bond

– Gross roll up. – Gains arising on surrenders are liable to income tax at marginal rates and social security taxes. – The gain arising on payment of the death benefit is liable to social security taxes. – Inheritance tax is payable on the death benefits.

Hong Kong (2019) QIntl Ireland dac and QIntl Isle of Man - Life bond

– Gains on surrender and death/maturity benefit payments are not subject to income tax or CGT. – There is no wealth tax. – IHT and gift tax do not apply.




http://www.quilterinternational.com/support-and-help/technical-help/internationally-mobile-solutions/


http://www.quilterinternational.com/articles/


India (2017) QIntl Ireland dac and QIntl Isle of Man - Life bond

– Gross roll up. – Gains arising on surrenders are liable to income tax. – Additional levies for education and tax surcharges are payable. – The death benefit is exempt from income tax. – Gift tax is payable by recipients subject to certain exemptions. – There is no inheritance tax and wealth tax in India.


‘Internationally mobile solutions’ sits in the Technical Centre (adviser part) of our website and provides useful information on India.

QIntl Ireland dac and QIntl Isle of Man - Redemption bond

– Gross roll up. – Gains arising on surrenders are liable to capital gains tax. – Short term capital gains arising within 36 months are liable to marginal income tax rates. – Long term capital gains arising after 36 months are liable to capital gains tax at 20%. – Additional levies for education and tax surcharges are payable. – Gift tax is payable by recipients subject to certain exemptions. – There is no inheritance tax and wealth tax in India.

Indonesia (2016) QIntl Ireland dac and QIntl Isle of Man - Life bond

– Gains made on surrender or when the relevant life assured dies are not subject to income tax and CGT. – Proceeds of a life policy paid to an individual not resident in Indonesia are not taxable in Indonesia. If the

proceeds are inherited there are no tax consequences in Indonesia, even if proceeds are or are not remitted to Indonesia.

– Wealth taxes do not apply. – Gift taxes do not apply.

Tax residencyIndonesian tax resident is defined as any individual who: – resides in Indonesia,– lives in Indonesia for more than 183 days in a

period of 12 months– in one fiscal year, lives in Indonesia and has the

intention to reside in Indonesia.Double taxation agreementsIndonesia does not have a double taxation agreement in place with either the Isle of Man or Republic of Ireland.TrustsIndonesian law does not recognise the concept of trusts. If a trust is used and the trust is irrevocable, the assets can be argued to no longer be owned by the settlor, and therefore a transfer of assets has taken place to the trust. If the trust is revocable, the assets are likely to be considered as still being owned by the settlor.

QIntl Isle of Man - Redemption bond

– Redemption policies are considered pure investment. Gains made on surrender or maturity are subject to income tax but they are not subject to CGT.

– Proceeds of a redemption policy paid to an individual not resident in Indonesia are not taxable in Indonesia. If the proceeds are inherited there are no tax consequences in Indonesia, even if proceeds are or are not remitted to Indonesia.

– Wealth taxes do not apply. – Gift taxes do not apply.

Malaysia (2019) QIntl Isle of Man - Life and Redemption bonds

– Income tax relief for Malaysia residents for premiums of life assurance for the taxpayer and/or their spouse. – Cash premiums should not be subject to tax. – Gains made on total surrender are likely to be a capital gain and not subject to tax in Malaysia. – Gains made on part surrender could be subject to income tax if received on a regular basis. – The death benefit payment is not subject to tax in Malaysia. – The maturity benefit is likely to be a capital gain and not subject to tax in Malaysia. – Wealth taxes do not apply. – IHT and gift tax does not apply.






Singapore (2019) QIntl Ireland dac and QIntl Isle of Man - Life bond

– Gains on surrender and death benefit payments are not subject to income tax or CGT. – There is no wealth tax. – IHT and gift tax does not apply.


South Africa (2018)

QIntl Ireland dac and QIntl Isle of Man - Life bond

– Gross roll up. – Chargeable gains are taxable on an arising basis. – Chargeable gains on surrender and death are liable to CGT. – 40% of gains are included in income. The maximum effective rate on gains is currently 18%. – Estate duty and donations tax are payable in South Africa. – There is no wealth tax in South Africa.


‘Internationally mobile solutions’ sits in the Technical Centre (adviser part) of our website and provides useful information on South Africa.


– Gross roll up. – Chargeable gains are taxable on an arising basis. – Chargeable gains on surrender and maturity are liable to CGT. – 40% of gains are included in income. The maximum effective rate on gains is currently 18%. – Estate duty and donations tax are payable in South Africa. – There is no wealth tax in South Africa.

Spain (2018) QIntl Ireland dac - Life bond (Spanish Collective Investment Bond only)

For other QIntl Ireland dac bonds refer to QIntl Isle of Man treatment below

– Gross roll up. – Personal income tax on savings income applies to gains made on surrender rather than on an annual

basis. – Personal income tax on savings income is payable on the death benefit when there is no beneficiary

nomination. – CGT does not apply. – Gift tax and IHT applies. – Wealth tax applies. Full details of the products from Quilter

International are available on our website.

QIntl Isle of Man - Life bond

– Subject to personal income tax and losses can be offset on an annual basis rather than deferred until surrender or when death benefit is payable.

– No CGT. – Gift tax and IHT applies. – Wealth tax applies.

Sweden (2018) QIntl Ireland dac and QIntl Isle of Man - Life bond


QIntl Ireland dac policies are considered Swedish K policies in Sweden. – Gross roll up. – Gains made on surrender and death benefit proceeds are free of tax. – Net yield tax applies annually to the policy. – IHT and wealth tax do not apply.

Full details of the products from Quilter International are available on our website. The ‘Key Investor Document/Tax and other important information for Sweden’ document and the Tax information for Sweden ‘Knowledge Direct’ article also provides useful information.






Taiwan (2019) QIntl Ireland dac and QIntl Isle of Man -Life and Redemption bonds

– Gross roll up. – Full surrender, part surrender and the maturity of a policy are regarded as offshore income and subject

to alternative minimum tax. – Death benefits paid on the death of a relevant life assured are subject to taxation. – Estate tax is due on the death of a policyholder. – Gift taxes apply. – Wealth taxes apply.


UAE (2019) QIntl Ireland dac and QIntl Isle of Man - Life bond QIntl Isle of Man - Redemption bond

– UAE is essentially a tax-free jurisdiction. – There is no income tax or CGT. – There is no wealth tax, gift tax or inheritance tax.


The Moving to the United Arab Emirates ‘Knowledge Direct’ article also provides useful information.

UK (2019) QIntl Ireland dac and QIntl Isle of Man - Life and Redemption bonds

– Gross roll up. – Gains made on surrender and death benefit proceeds are liable to income tax under the chargeable

event rules. – 5% tax deferred withdrawal allowance can be used to defer tax liabilities. – Time Apportionment Relief and Top Slicing Relief can be used to reduce the tax payable. – CGT only applies if the policy is sold. – IHT applies. – Wealth tax does not apply. – Personal Portfolio Bond taxation applies.


‘Internationally mobile solutions’ sits in the Technical Centre (adviser part) of our website and provides useful information on the UK.

The ‘UK taxation of offshore bonds, part 1, part 2 and part 3’ as well as Bond tax for an investor returning to the UK ‘Knowledge Direct’ articles also provide useful information.

USA (2018) QIntl Ireland dac and QIntl Isle of Man - Life bond


– We have only reviewed the position for individuals using an international pension with a Maltese pension provider holding a bond as an asset of the scheme.

– A double taxation agreement exists between Malta and the USA which allows gross roll up on retirement savings.

– USA tax is deferred until retirement. – The offshore bond is a suitable investment solution for the international pension

provider to invest into.


‘Internationally mobile solutions’ sits in the Technical Centre (adviser part) of our website and provides useful information on the USA.







www.quilterinternational.comCalls may be monitored and recorded for training purposes and to avoid misunderstandings.

Quilter International Isle of Man Limited is registered in the Isle of Man under number 24916C. Registered and Head Office: King Edward Bay House, King Edward Road, Onchan, Isle of Man, IM99 1NU, British Isles. Phone: +44 (0)1624 655 555 Fax: +44 (0)1624 611 715. Licensed by the Isle of Man Financial Services Authority.

Quilter International is registered in the Isle of Man as a business name of Quilter International Isle of Man Limited.

Quilter International is the registered business name of Quilter International Isle of Man Limited Singapore Branch. Quilter International Isle of Man Limited Singapore Branch, CapitaGreen #06-02, 138 Market Street, Singapore 048946. Phone: +65 6216 7990 Fax: +65 6216 7999.

Registered in Singapore Number T08FC7158E. Authorised by the Monetary Authority of Singapore to conduct life assurance business in Singapore. Member of the Life Insurance Association of Singapore. Member of the Singapore Finance Dispute Resolution Scheme.

Quilter International Ireland dac is regulated by the Central Bank of Ireland. Registered No 309649. Administration Centre for correspondence: King Edward Bay House, King Edward Road, Onchan, Isle of Man, IM99 1NU. Tel: +353(0)1 479 3900 Fax: +353(0)1 475 1020.

Registered and Head Office Address: Hambleden House, 19-26 Lower Pembroke Street, Dublin 2, D02 WV96, Ireland.

VAT number for Quilter International Ireland dac is 6329649S.

Quilter International is registered in Ireland as a business name of Quilter International Ireland dac.

14006/INT20-0965/November 2020

The value of investments may fall as well as rise in value and investors may not get back what they paid in.

This document is based on Quilter International’s interpretation of law and tax practice as at November 2020. We believe this interpretation to be correct, but cannot guarantee it. Tax relief and tax treatment of investment funds may change in the future. The value of any tax relief will depend on the investor’s individual circumstances.

Documents

Country guide to tax on Quilter International bonds · 4 Country guide to tax on Quilter International bonds Quilter International India (2017) QIntl Ireland dac and QIntl Isle of