In an effort to keep our clients up to date in the new international regulatory processes on offshore practice, we are hereby proposing that our firm is now providing tax optimization structures under the newest scheme to benefit the adequate , safe operation of your tax structures.


In some jurisdictions THE TERRITORIALITY PRINCIPLE applies, whereby no local corporation tax is levied on its worldwide operational income and profits of a company incorporated under such jurisdiction.

Despite the fact a well managed company may be incorporated under any jurisdiction, we do recommend to use, those that are considered as jurisdictions of countries that cooperated with OECD, i.e. Panama, which has the largest shipping fleet in the world.

For example in Panama we have a wide diversity of structures, to wit:

• Panama Offshore Companies under the patronage of Law 32, 1927
• Panama: S.R.L or Limited Liability Company
• British Virgin Islands International Business Company
• Belize: International Business Company


These jurisdictions offer a mostly favorable tax status.

Such structures are often exempted from local corporate tax on profits earned beyond it legal jurisdictional boundaries, or subject to a nominal tax payment. Consequently, a GerliCo., structured semi-offshore companies will require filling of a local tax report on its locally earned income and capital gains within the jurisdiction (i.e. from local generated income) and not on its foreign income.

Not necessarily does an semi-offshore companies has or is blacklisted, thus providing therefore a higher acceptance under a clear business reputation with its jurisdictions tax authorities clearance. Furthermore, most of these jurisdictions have entered into double tax treaties, which under all means are suitable for international tax planning.

As examples of semi offshore companies we may provide such from the following jurisdictions:
• Hong Kong Private Company Limited by shares
• Wyoming/Delaware Limited Liability Company
• Cyprus Company with VAT
• Panama Company with local VAT or European VAT

October 3rd , 2008


Dear Sir,

Further to your instructions to us to incorporate and administrate the above named company we are enclosing documents pertaining to the company.
Although you may wish to keep these documents, we suggest that you return them to us for safe keeping or you may wish to lodge them with a solicitor. Should you not have a solicitor you want to entrust these papers with, we can recommend one to you. In the event you do not lodge the documents for safe keeping with an independent person, please keep them in a very safe, secure and confidential place.
We enclose the following documents:

1. Articles of Incorporation
2. Letter of Provision of Administration for the referenced company
3. Standard Terms of Business
4. Declaration of Trust and Benefit Ownership
We also request that you present to us a “Letter of Wishes”. This letter should instruct who or what you wish the interest in the company to be passed to, in the event of your untimely demise.
Should you require any assistance or additional information, please contact us at your convenience.

Yours sincerely,

Ismael Gerli

Gerli , I. 2008, WELL MANAGED OFFSHORE COMPANIES , Linfus Bogota, Panama .


Foundations Advantages.doc

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