英语论文网

charge any tax on the profits of Metronomic Distribution Co.  Instead, there is a modest annual company registration fee. It pays dividends to Metronomic Holdings Co as and when directed to do so by Metronomic Holdings Co, but most of the  profits are retained within Bermuda or lent to Metronomic Finance Co in Luxembourg.

Metronomic Finance Co (Luxembourg): this is the group finance company.  It borrows money from external banks and, at very favourable rates,  from Metronomic IP Co and Metronomic Distribution Co. The money borrowed is lent to the manufacturing companies in the group at interest rates which are a little higher than arm’s length rates.   Metronomic Finance Co benefits from Luxembourg’s favourable tax regime for group finance companies, which has the result that very little corporation tax is paid in Luxembourg.  Dividends representing about half of the profits after tax are paid up to Metronomic Holdings Inc at the instruction of Metronomic Holdings Inc each year.

The changing situation形势的变化

Because of pressures from the OECD, Ruritania is planning to increase its effective corporation tax rate to 25%, will introduce anti-haven legislation and will insist that company accounts be made freely available to the public, including the tax authorities in the UK and the US. Ruritania also plans to enter into Tax Information Exchange  Agreements with all the OECD member countries. As a result, the Board of Metronomic Holdings has decided that Metronomic Holdings Inc is going to have to cease to be tax  resident in Ruritania and become tax  resident elsewhere. 

Another reason for the intended change is that Ruritania does not have any double tax treaties.  This means that when payments are made from the other companies in the group to Metronomic Holdings Inc in Ruritania, withholding taxes are levied at the rates laid down in domestic law, which are quite high. 

Although the Board of Metronomic Holdings Inc realises that it will be unable to find a new location for Holdings Co which offers the level of financial secrecy that has been enjoyed until now in Ruritania, it believes that it can find an alternative location that will be more attractive than the planned new tax regime in Ruritania.

The Board has also noted that the tax situation in China is changing and wishes to reduce the activities carried out in China by setting up a new manufacturing facility in another country, but with the same pricing arrangements with Metronomic IP CO and Metronomic Distribution Co. and with the same financing arrangements with Metronomic Finance Co. 

The Board would like to have both the new holding company and the new manufacturing company in the same country.

The planned research into possible suitable countries

The Board members have arranged for a delegation from the governments of a number off countries to make a visit to Ruritania to explain to the Board of Metronomic Holdings Co why their country would be a suitable location for the new holding company and for any new manufacturing company.

The delegations  will consist of small groups of high ranking civil servants who will make separate presentations to the Board on:

The general economic and political  climate in their country<本论文由英语论文网提供整理，提供论文代写，英语论文代写，代写论文，代写英语论文，代写留学生论文，代写英文论文，留学生论文代写相关核心关键词搜索。