Case Studies

White November guides start-up entrepreneurs through the legal, financial, and economic aspects of running a business.

We give our clients honest and constructive feedback, and we invest time in meeting with our clients and discussing their business ideas.

Two years ago we started to guide small group of software developers. Our goal was to propose cost effective corporate structure and services. Keeping the start-up costs low, outsourcing the tax, accounting, corporate and legal issues to White November resulted in steady growth of the company. Our clients were then able to concentrate on building their software and business development. Today we are discussing terms and conditions with new investors for these clients.

We can help you establish the most tax-effective structure for your business as well as advising you on the overall considerations for setting up a business including:

• Whether you should incorporate or be a sole trader
• What kind of incentives you can apply for
• The solutions available for your future investors
• The most tax efficient structure for you to draw funds from the business
• What reliefs are available if anything goes wrong

Mr. Johannsson and Mr. Nilsson are two shareholders and ultimate beneficial owners of a Swedish Company that produces and sells köttbullar, the famous Swedish meatballs. They would like to expand their business and accept a new shareholder, Mr. Andersson.  It is important for all parties to mitigate their tax exposure on the share transfer transaction.

Cyprus Holding Company

For this reason, they decide first to transfer the shares of the Swedish Company to a Cyprus Holding Company and sell part of the shares in the Cyprus Holding Company to Mr. Andersson. The payment for the share stake in the Swedish Company will be received by the Cyprus Holding Company, which will allow the parties to increase tax efficiency as such transaction in Cyprus is tax free. Mr. Andersson will receive part of the shares in the Cyprus Holding Company.

Business expanding in the EU

Few months later, during a meeting of the shareholders, the three were considering the opportunity to expand their business in the EU by purchasing bigger factory building in Sweden. With the money received from the share transfer and profits received form the Swedish Subsidiary they decide to purchase such property and rent it out to the Swedish Subsidiary.

After a couple of years all three of them decide to:

• Sell the bigger factory to a buyer from Sweden– the Cyprus Holding Company will receive Capital Gain from the sale of the asset – no further taxation in Cyprus.
• Sell the Swedish Subsidiary to a Corporation from China – transaction in Cyprus, sell of shares of a Swedish Subsidiary is also a Capital Gain – no further taxation in Cyprus.
• Retire in Portugal, their favourite European Country, with the Non-habitual residence regime which will allow them to take out dividends from the Cyprus Holding Company tax free.

We help plan companies next growth phase:

Many companies do not think about taxes until it’s too late to take full advantage of the opportunities available. Our cross border knowledge and experience working with different tax jurisdictions enable us to forge good working relationship with all parties involved and keep clients well-informed.

Our client in this example was a large pharma company looking to relocate from Switzerland to Malta. Our work concentrated on implementing the right corporate and tax structure as well as efficient and risk mitigating asset separation. We also undertook application for incentives available for all new companies entering the Maltese market.

We were able to proactively manage the diverse legal and audit firms providing tax advice and find solutions that positioned our client well, while at the same time keeping costs and complexity under control.