Presentation by Withers LLP to the American Chamber of Commerce in Bishkek, Kyrgyzstan 28 October 20

1
Presentation by Withers LLP to the American
Chamber of Commerce in Bishkek, Kyrgyzstan 28
October 2009

• Issues for CIS companies accessing western
  capital markets including a critical comparison
  between London, New York, Hong Kong and other
  listing venues

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Tax and structuring issues
(0 DWT)
Isle of / BVI Man co co
(0 tax)
Article 10223 Tax DWTCode
100
Kyrgyz operating company
(10 profit tax)
(Local business)
3
(No Transcript)
4
Manxco 2
0 tax
Manxco 1
0 tax
Netherlands co-op
0 tax
Netherlands BV/NV
0 tax
Austrian Holdco
0 tax
5 DWT under Art 102(a) KYG/Austrian DTA
Kyrgyz operating company
(10 profit tax)
(Local business)
5
0 DWT
0 tax
BVI / Isle of Man
0 DWT
UK company / Cyprus company
0 tax
0 DWT
Kyrgyz operating company
(10 profit tax)
6
Institutional trust
Protector
Purpose trust
100
Private trust company
Family trust
100
Manx Holdco
100
(Underlying corporate structure)