SLG Newsletter: May 2021

Dear Friends and Clients,

Treaty shopping is a thorn in the side of many European tax authorities. However, as we have already explained in several webinars, a fortunately-set-up legal structure that spans several countries can lead to considerable tax savings. For example, the double taxation treaty between the UAE and Germany is widely inapplicable due to residency requirements. On the other hand, there is a double taxation treaty between Singapore and Germany which can be applied. In simple terms, if dividends from a UAE company are distributed to a Singapore holding company and from there sent on to Germany, the unpleasant provisions of the grossly disadvantageous double taxation treaty between the UAE and Germany can be avoided. However, here, the financial authorities push the bar of the economic approach so that the Singapore-based holding company may not only generate income from capital assets, but must actually be active in operations.

Further measures are to be taken that the provisions in European tax laws e.g. treaty shopping and economic approach, are not applied. Singapore also has the advantage of the local taxation system and not the world taxation system which means that even the 17% flat tax on corporate profits does not apply if the dividends of the UAE subsidiary do not flow into a Singaporean account. Another point worth noting is that Singapore residents are exempt from tax on overseas dividend income. The same applies to foreigners who have an account in Singapore. We can also open bank accounts for Singapore companies in Hong Kong, Mauritius and other countries through our Singapore branch so that tax optimization is guaranteed.

This is of particular interest to all those entrepreneurs who may generate tax-free profits in the UAE but cannot distribute them directly to shareholders residing in ahigh-tax country. Customized constructions for legal tax avoidance are our specialty. For the formation of a Singapore company, you don’t have to appear in person, everything can be done online. Even for opening bank accounts with certain banks, our firm is entitled to legalize signatures and documents.


Theodor Strohal


The presentations can be viewed any time by visiting our homepage:

For the ones who would rather listen than read we also provide short video versions of the webinars:

Compliance, Compliance: ESR, CRS, UBOR, MDR
•Restructuring under UAE Insolvency and Bankruptcy Laws
•The Advantages of a Second Residence
•Asset Protection
The UBO Issue

Ras al Khaimah supports new corporate structures

RAK ICC and RAK SME have signed a MoU to provide opportunities for entrepreneurs and SMEs to create a practical corporate structure for their businesses. The MoU aims to promote RAK ICC and its services to SMEs by providing them with guidance on the advantages of structuring investments through RAK ICC companies and offering a fast, easy and cost-effective registration process with minimal requirements.

Not only ghosts attract tourists in RAK

Ras Al Khaimah, which has a history dating back 7,000 years, is home to some of the oldest towns in the UAE. One of them is Jazeera Al Hamra, the last authentic fishermen’s village abandoned in the middle of the 20th century. It is believed that this village is now haunted by ghosts, with several stories popping up on social media time and time again. “I tell you there are no ghosts now,” Raki Phillips, CEO of Ras Al Khaimah Tourism Development Authority, says with a smile.

Jazeera Al Hamra has been fully restored to it’s former self. “It is now a temporary UNESCO heritage site.”

Visitors can walk through its alleyways the way its residents used to back in the beginning of the 19th century. One can step inside old homes and explore a fort.

2,000 jobs to be created in RAK

The RAK tourism authority CEO said the emirate’s hospitality sector has 6,700 keys now and another 2,000 will be added in the next six to seven months. “We have the Hampton by Hilton on Marjan Island, InterContinental, Radisson and Movenpick resorts coming up in the emirate. All beachfront properties are in prime locations,” he said. These new properties will create around 2,000 jobs.

In 2019, RAK received over 1.1 million visitors. “Globally, the decline in tourism was 75 per cent in 2020 but in RAK, it was only 25 per cent. We welcomed over 800,000 tourists last year and in 2021 we are forecasting over 950,000 visitors,” Phillips said.

“Ras Al Khaimah is the best place to escape from the hustle and bustle of the city and to get nature-driven experiences, mountains, fresh air and mangroves. It is quite good for a romantic getaway and the temperature is 10 degrees cooler when you go up in the mountains.”

New programs in Dubai Healthcare City

Dubai SME has announced the launch of a new business incubator ‘Ztartup,’ in Dubai Healthcare City with two specialized programs. The new incubator, located in Wafi Residences, is dedicated to healthcare technology, including digital media and augmented & virtual reality used in healthcare, digital emergencies, and safety technology.

Two specialized programs are:

  1. Business Incubation
  2. Business Accelerators


  • connecting entrepreneurs to a network of specialists and mentors to help develop their products and services as well as varied courses, training, workspaces, business start-up packages, etc.  required in each phase of the project,
  • providing specialized laboratories that help entrepreneurs to design prototypes for their projects, and
  • help entrepreneurs develop and improve smart phone applications for the healthcare and fintech sectors.

Russian investments in UAE in information technology

The UAE-Russian Business Council has discussed ways of boosting cooperation in the digital economy between the two countries, as well as encouraging mutual investments in information technology, cloud computing, artificial intelligence (AI) and smart services across all economic sectors. The discussion was represented by Abdullah Sultan Al Owais, Chairman of the UAE-Russia Business Council and Chairman of the Sharjah Chamber of Commerce & Industry, while the Russian delegation was represented by Sergey Gorkov, Chairman of Russia-UAE Business Council. The trade between the two countries has significantly increased in recent years, and Russia has become the UAE’s lead trading partner in Eastern and Central Europe, while the UAE maintains its position as Russia’s key trading partner in the Gulf region. Gorkov stated that Russian businessmen and investors have a special interest in the UAE, which is a key economic destination for Russian companies, due to its diverse investment environment and attractive economic and commercial climate.

Far East:

Thailand will ease visa and stay permit rules

The Government of Thailand is considering revamping immigration rules this year to help expats and long-term tourists to stay in the country. Plans include improving regulations on immigration, visa applications and work permits for foreign experts, including relaxing the requirement for foreign workers to report their whereabouts to authorities every 90 days. Authorities believe that making it easier for foreign companies to bring in skilled workers and for western retirees to stay in Thailand will boost their economy. The new framework will also include inducements for foreign investors such as corporate income-tax cuts, relaxed property-holding rules and incentives for retirees and start-up companies.

Master plan “Singapore IP Strategy 2030”

 The 10-year Blueprint initiative was announced by the Second Minister for Law and involves a task force comprising of at least 10 government agencies, including the Intellectual Property Office of Singapore(IPOS). The plan will be implemented on the ecosystem, enterprise and individual levels.

It aims to:

  • strengthen Singapore’s position as a global hub for intangible assets (IA) and intellectual property (IP),
  • maintain the Republic’s strength “as a top-ranked IP regime” so that investments can continue to come into the country,and
  • create “good jobs and valuable skills” in the IA and IP sector.

The masterplan builds on a previous one announced in 2013 and updated in 2017. A next-generation IP filing system to support innovators and enterprises is expected to be launched by the middle of 2022.

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