1. RAK INTERNATIONAL CORPORATE CENTRE
Government of Ras Al Khaimah, United Arab Emirates
April 2019

2. UNITED ARAB EMIRATES - A WORLD CLASS JURISDICTION
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#1 on ease of doing business index-Mena Region
# 8 largest oil producer in the world
# 11 in the world bank’s annual ease of doing business ranking
# 2017 GDP per capita US$40,000 (Same as Germany)
#2 in the world government trust index
Credit ratings : S&P AA, Moody’s AA2 ( same as Hong Kong, France, UK and South Korea)
# 27 Amongst 140 countries in the global competitiveness ranking ( highest in the region: higher than Malta (36), Cyprus (44), Mauritius (49), Panama (64) and Seychelles (74)
UAE ranked #2 in the world in terms of signed DTTs and #1 among the Arab nations.
Mature banking system ( over 50 national and international banks)

3. compliance and regulations
The UAE has been working tirelessly in the past few years to combat money laundering and financing of terrorism, and to eliminate the misuse of tax agreements and tax evasion by signing several international agreements including with the OECD and The Global Forum on Transparency and Exchange of Information for Tax Purposes. These measures include:
Membership of the Middle East and North Africa Financial Action Task Force
FATCA – The UAE signed Model 1 B IGA on 17 June 2015
the Convention on Mutual Administrative Assistance in Tax Matters,
the Multilateral Competent Authority Agreement to facilitate the automatic exchange of information between the concerned authorities
the agreement on the exchange of Country-by-Country reports (MCAA CbCR).
It also joined the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) by signing the Multilateral Convention (MLI) agreement.
The UAE remains firmly committed to its long-standing policy of meeting the highest international standards on taxation, including the OECD’s requirements, and will continue to update its domestic legislative framework in this regard. In furtherance of this commitment, the UAE has shared with the EU a detailed timeline of actions that it is currently implementing in accordance with its sovereign legal process and constitutional requirements.”
For all these reasons we believe the UAE will be off the Blacklist sooner rather than later

4. Mauritius and THE UAE Embarking on a new era of economic collaboration
Both countries have signed a Double Tax Avoidance Agreement (DTAA) and an Investment Promotion and Protection Agreement (IPPA) which has resulted in more than USD 10 Billion of investment flows between Mauritius and the UAE structured through the Global Business Sector.
Investment from the UAE into the Mauritian economy represents 4% of total FDI to Mauritius
The main sectors of interest being Real estate, Manufacturing, the Hospitality industry and Business services.
Mauritius can be a strategic partner to UAE companies venturing into Africa & the UAE via RAK ICC can be the gateway into the GCC and the rest of the Arab world

5. Rak international corporate centRE (RAK ICC)
RAK International Corporate Centre is a Corporate Registry based in Ras Al Khaimah, UAE and is the 2017 amalgamation of two company registries, RAK IC and RAK Offshore, which have been operating since 2006 in Ras Al Khaimah.
RAK International Corporate Centre (RAK ICC) operates in the picturesque Emirate of Ras Al Khaimah, United Arab Emirates. The Emirate is also known as the ‘Rising Emirate’ having gained a reputation for its recent economic growth and emerging business opportunities, including maintaining up to date regulatory and international technical standards as and when these develop
RAK ICC a cutting edge, globally, up to date Corporate Centre
100% compliant with new worldwide reporting standards

6. GLOBAL APPEAL - Over 30,000 companies with Shareholders from over 160 countries
INCORPORATIONS
India 12%
United Kingdom 9%
United Arab Emirates 7%
France 6%
Italy 4%
Pakistan 3%
Germany 3%
Canada 2%
Russian Federation 2%
Lebanon 2%
Others (156 Countries) 50%

7. AAA network of qualified agents & SERVICE PROVIDERS with regional & global reach
Regular training is provided to the registered agents staff on relevant matters including updates on compliance, documentation, AML and KYC as per the international standards.

8. WHY RAK ICC? Corporate Features Legal Features Other Features
100% foreign ownership
One day incorporating process;
No restrictions on number of shareholders;
Corporate Director is permitted
No office requirement;
No attestation required for corporate documents;
Cost efficient registration and renewal fees;
No requirement to file financial accounts
No requirement for minimum capital;
Constitutional documents can be issued in dual languages
Access to a broad range of UAE Double Tax Treaty network;
Ability to open bank accounts locally and internationally
USD freely available. Local currency pegged to USD
Common law regulations with access to DIFC and ADGM courts;
Variety of legal structures and different products available for different usages;
No restriction on capital repatriation;
Migration or Continuance of Existing Corporate Entities from various jurisdictions
Different classes of shares and the ability to register the share pledge
Corporate Features
Legal Features
Other Features

9. RAK ICC PRODUCTS, SERVICES & Uses
COMPANY LIMITED BY SHARES
HOLDING COMPANIES AND SPVS
UNLIMITED COMPANY
JOINT VENTURE COMPANIES
COMPANY LIMITED BY GUARANTEE
IP HOLDING COMPANIES
SEGREATED PORTFOLIO COMPANY
RESTRICTED PURPOSES COMPANY
TRADING/INVOICING COMPANIES AND IBCS
TRANSFER OF DOMICILE
FAMILY OFFICE STRUCTURES
REGISTER WILLS AT RAK ICC
PE & FUND STRUCTURES

10. Structured solutions - Substance & More
RAK ICC PREMIUM PRODUCT: Premium Product is a collaboration between RAK ICC and Ras Al Khaimah Economic Zone (RAKEZ) that allows offshore companies registered with RAK ICC to carry out activities onshore by establishing a subsidiary at RAKEZ.
PARENT COMPANY / INVESTOR
RAK ICC Holdco
BENEFITS
Companies are treated as business enterprise of substance
Investors can open bank accounts locally and internationally
Option to lease a physical facility from RAKEZ
Enjoy Double Taxation Treaty benefits
Global trade and investments
Eligibility for a UAE Residence Visa
RAKEZ Subsidiary
OpCo

11. Special purpose vehicles (SPVs)
SPVs are corporate vehicles with several attractive features established for the purpose of various usages mainly for securitization and isolating financial and legal risk by ring-fencing assets and liabilities. SPVs can be established as subsidiaries, project or joint venture vehicles to ensure that only those assets related to a transaction are exposed to the liabilities associated with that transaction. As the key feature of an SPV is its separate legal personality, claims by the SPV’s creditors cannot attach to the assets of the SPV’s shareholders or any of its sister companies.
PARENT COMPANY / INVESTOR
(Mauritius)
RAK ICC SPV
BENEFITS
Structured finance transactions
Securitisations
Asset holding and transfers
Financing and raising capital
Ring-Fencing and risk sharing
Fractional Ownership structures
Loan agreement
Lender / Bank
Share Pledge agreement
Financing

12. Private Clients solution
A family office is an entity (or multiple entities) established by a wealthy family to manage its wealth and, in some cases, to provide family members with services such as tax and estate planning services and legal services. Family offices may also include a philanthropic arm for supporting the family’s charitable, social and educational interests
Family Beneficiaries
Foundation / Private Client
(Mauritius)
RAK ICC Family Office SPV
BENEFITS
Foundation as shareholder
Estate Planning
Tax benefits
Asset Protection
DIFC Will
Real estate
Operating Co
Listed equity

13. Segregated Portfolio Company
A Segregated Portfolio Company (or SPC), sometimes referred to as a protected cell company, is a company which segregates the assets and liabilities of different classes (or sometimes series) of shares from each other and from the general assets of the SPC.
Segregated Portfolio assets comprise assets representing share capital, retained earnings, capital reserves, share premiums and all other assets attributable to or held within the Segregated Portfolio. Possible to structure a joint solution between Mauritius and UAE
BENEFITS
Separate Legal Personality
Limited Liability of shareholders
Up to ten segregated portfolios
Separation of Liability
Sub bank accounts can be established

14. passive holding companies
RAK ICC Passive holding company can be used to ring-fence investments, public and private equity stakes and other assets
ILLUSTRATION OF THE USAGE OF PASSIVE HOLDING COMPANIES
PARENT COMPANY / INVESTOR
Listed equities
Publicly traded bonds
Owns a passive holding company in RAK ICC
Non-controlling equity stake in private UAE or int’l business
RAK ICC HOLDCO
MAIN BENEFITS TO CLIENTS
Provide an effective structure for ease of ownership transfer across different shareholders (sales of business & inheritance planning)
Security for finance based on corporate valuation based on underlying asset holdings
Offer an operating structure for pooling of assets for management and reporting purposes
Maintain privacy of wealth

15. active holding company- attractive for a range of purposes (EXAMPLES OF USE CASES)
MANUFACTURER USES STRUCTURE TO MANAGE ASSETS
Gateway for expanding ME business, with physical and cultural proximity
Effective operating structure for management and reporting purposes
Ease of ownership of assets across countries, especially those facing asset transfer restrictions due to political sensitivity
Ease of ownership transfer
PARENT COMPANY
Oil refinery in Kuwait
Factory in Egypt
Factory in Bahrain
Owns a Holding Company in RAK ICC
RAK ICC FREEZONE HOLDCO
KUWAIT COMPANY
EGYPT COMPANY
BAHRAIN COMPANY
MANUFACTURER SETS UP REGIONAL TREASURY FUNCTION
Redeploy cash, improve treasury efficiency and manage financial risk
Enable financial due diligence for local deals
Facilitate foreign currencies payments especially for clients from countries with foreign exchange restrictions
Exemption from custom duties on trades
RAK ICC FREEZONE FINCO
Parent company trading/sourcing/ owning assets
CHINA
Raw material in Philippines
Sales in ME
Subsidiaries in Egypt $
Owns a Financing Company
JV PARTNERS ESTABLISH HOLDCO TO ACCESS INDEPENDENT DIFC COURTS
Certainty and clarity of legal system
Swifter and more efficient resolutions to court proceedings – less prone to bribery and lengthy processes
General preference for Common Law systems over Sharia Law for conducting business
Cultural and physical proximity
Sets up joint venture
INVESTOR IN RUSSIA
INVESTOR IN EGYPT
For investment in other countries
Asset in Oman
Projects in South Africa
RAK ICC FREEZONE HOLDCO

16. ACTIVE HOLDING STRUCTURES
INTERNATIONAL TRADING AND PROCUREMENT COMPANIES MANAGE SOURCING IN THE REGION
Simplicity of management
Leverage scale to lower cost
Use UAE as part of supply chain to complete trade route
Tax optimisation opportunities
RAK ICC FZ / trading company
Owns car components production units
GERMANY
Petroleum in Saudi Arabia
Aluminium in UAE
OTHER MIDDLE EASTERN COUNTRIES
RAK ICC
Steel in India
Owns a trading company $
Sell via intemediary1
Purchase from
E-COMMERCE COMPANY CONDUCTS BUSINESSES INTERNATIONALLY
Higher level of control and oversight over distribution compared to using distributors
Use UAE as part of supply chain to complete trade route
Tax optimisation opportunities
Suppliers
MULTIPLE COUNTRIES
OTHER COUNTRIES
Egypt
Libya
UAE $
RAK ICC
Sell via intermediary1
Sets up distribution unit
RAK ICC FZ / trading company
INTERNATIONAL DIGITAL SERVICE PROVIDER SETS UP REGIONAL HUB
Physical access to regional market and closeness of time zone with major Asian and European markets
Low cost of living
Tax optimisation opportunities
Digital service provider
Staff work for
INDIA
DISTRIBUTORS / CUSTOMERS $
RAK ICC
RAK ICC FZ / trading company
Freelancer.com
Clients in Kuwait
Clients in UAE

17. THE UAE Double Tax Treaty Network (DTTs)
The UAE Ministry of Finance has taken important steps in this direction and has signed as many as 210 tax agreements to date (including 123 agreements to avoid double taxation and 87 agreements to protect and promote investment).
List of UAE Double Tax Treaties (Income and Capital)
In-Force DTTs (89)1
Pending DTTs (20)
Signed DTTs (but not yet ratified) (8)
Under negotiation (8)
Africa (13)
Uzbekistan
Belgium
Poland
Ratified by both states (6)
North America
Africa
Algeria
Asia (17)
Bosnia and Herzegovina
Portugal
Bermuda
Angola
Chad
Comoro Islands
Bangladesh
Bulgaria
Romania
Burundi
South America
Mali
Malawi
Egypt
Brunei
Cyprus
Russia2
Ethiopia
Argentina
Uganda
Tanzania
Guinea
China (P.R.C.)
Czech Republic
Serbia
Mauritania
Ecuador
Zimbabwe
Asia
Kenya
Hong Kong
Estonia
Slovakia
Middle East
Paraguay
Europe
Mongolia
Mauritius
India
Finland
Slovenia
Iraq
San Marino
Nepal
Morocco
Indonesia
France
Spain
Palestine
Caribbean
Mozambique
Japan
Georgia
Switzerland
Antigua and Barbuda
Guernsey
Senegal
Korea (Rep.)
Germany
Ukraine
Croatia
Central America
Seychelles
Malaysia
Greece
United Kingdom
Ratified by the UAE (14)
Costa Rica
Peru
South Africa
Maldives
Hungary
Oceania
Sudan
Pakistan
Ireland
Barbados
Benin
Colombia
Australia
Tunisia
Philippines
Italy
Cameroon
Singapore
Jersey
Canada
Equatorial Guinea
Jordan
Sri Lanka
Kosovo
Gambia
Lebanon
Thailand
Latvia
Mexico
Libya
Syria
Turkey
Liechtenstein
Panama
Nigeria
Yemen
Vietnam
Lithuania
Rwanda
Central Asia
Europe (41)
Luxembourg
Uruguay
Azerbaijan
Albania
Macedonia
Venezuela
Saudi Arabia
Kazakhstan
Andorra
Malta
Kyrgyzstan
Armenia
Moldova
Fiji
St. Kitts and Nevis
Turkmenistan
Austria
Montenegro
New Zealand
Tajikistan
Belarus
Netherlands
Belize
Strategy& analysis, Tax Notes database of in-force treaties as at 31 August 2018, subject to change.

18. Comparison of standard corporate tax rates1
U.A.E.
MALTA
CYPRUS
BVI
HONG KONG
SINGAPORE
MAURITIUS
SEYCHELLES
CORPORATE INCOME
0%1
5%2
12.5% 0%
8.25/16.5%3
17%5
15%6
0%8
CAPITAL GAINS
0%13
0%10
0%12
DIVIDENDS
3/15%9
INTEREST INCOME
0/35%11
0/8.25%4
3/15%7
10%
1) Oil and gas exploration companies and branches of foreign banks are subject to corporate income tax
2) Official rate is 35% but the effective rate is 5% due to the imputation system
3) First HKD2m taxed at 8.25% and any profits above that taxed at standard 16.5% rate-Source based as opposed to world-wide basis of taxation
4) Interest income derived from debt instruments with a maturity period of <7 years is taxed at 8.25%; interest income with a maturity period of 7 years or longer is tax-exempt
5) Different exemptions levels (e.g. up to 100% for the first SGD 100,000 of taxable income) are put in place for new businesses and start-ups
6) As at January GBC2 Companies have been abolished. GBC1 Companies have been replaced by authorized companies. Companies are taxed at 15% less an 80% credit- subject to approved substance requirements.
7) Interest income received from abroad by a company resident in Mauritius (Domestic) is subject to 15% tax rate. Interest income received from abroad by a GBC1 company is subject to tax at an effective rate of 3%. With effect from 1 January 2019, the deemed FTC regime available to GBC1 companies has now been abolished and foreign-source interest income not allowed as a deduction in the source country will qualify for an 80% partial exemption on the gross amount received, subject to substance rules
8) The rate for Seychelles resident companies is 25 / 30%, but International Business Companies (“IBCs”) are exempted from corporate tax
9) Dividend income received from abroad by a company resident in Mauritius (Domestic) is subject to 15% tax rate. Dividend income received from abroad by a GBC1 company is subject to tax at an effective rate of 3%. With effect from 1 January 2019, the deemed FTC regime available to GBC1 companies has now been abolished and foreign-source dividends not allowed as a deduction in the source country will qualify for an 80% partial exemption on the gross amount received, subject to substance rules
10) Standard capital gains tax is 20% but company shares are exempt, unless there is Cyprus residential property in the structure
11) 0% for passive interest and 35% for active interest income (effectively 0-10%)
12) 0% capital gains tax. Certain transactions are taxed as corporate in tax instead of capital gains, such as any gains derived from the sale of shares held for less than six months
13) Dividends and Capital gains are subject to corporation tax in Malta; however, due to the Participation Exemption the effective tax rate is 0%. Dividends and Capital Gains are subject to income tax (at normal rates of corporate income tax of 35%).
Source: PwC Tax Summaries, EY, Deloitte, PKF

19. No BITs with any countries
Comparison of investment protection through Bilateral Investment Treaties (BITs) 2
U.A.E.
MALTA
CYPRUS
BVI
HONG KONG
SINGAPORE
MAURITIUS
1SEYCHELLES
U.K. Y Y3
No BITs with any countries
GERMANY
INDIA *Y
CHINA
SOUTH AFRICA
PAKISTAN
SRI LANKA
SAUDI ARABIA
OMAN
TURKEY
EGYPT
TANZANIA
ETHIOPIA
2*Y
KENYA
1) Seychelles signed BIT’s have not been put in force for many years (Egypt – Signed 2002, China – Signed 2007, India – Signed 2010)
2) *Y indicates the BIT has been signed but is not yet in force
3) Investor protection offered under the Treaty on functioning of the European Union; No BITs in place
Source: Investment Policy Hub (UNCTAD)

20. No BITs with any countries
Comparison of investment protection through Bilateral Investment Treaties (BITs) 2
U.A.E.
Malta
Cyprus
BVI
Hong Kong
Singapore
Mauritius
Seychelles
France Y Y2
No BITs with any countries
Italy
Canada
Brazil
Mexico *Y
Colombia
Argentina
*Y indicates the BIT has been signed but is not yet in force
Investor protection offered under the Treaty on functioning of the European Union; No BITs in place
Source: Investment Policy Hub (UNCTAD)

21. RE-DOMICILIATION Opportunities
MAJOR ADVANTAGES
Companies could maintain its existing legal status
Companies could preserve its operational and banking history
Access to common law courts
Wills registration to protect the assets and shares in the name of the company
REASONS FOR REDOMICILIATION
Traditional Offshore jurisdictions are under pressure (competition ,regulatory issues & Substance).
Finding a valuable alternative to jurisdictions traditionally labelled as “offshore center” facing extreme scrutiny internationally
Evolving client priorities are driving a shift from traditional offshore centres to high quality well-regulated mid-shore and onshore centres.
Companies are increasingly concerned with the reputational risks associated with the choice of jurisdiction.

22. REDOMICILIATION TO UAE
ADVANTAGES:
Additional viable option for Mauritius GBCs; Win-Win solution
zero tax jurisdiction with extensive network of tax treaties
full repatriation of capital and profit
recognized financial hub presence of internationally recognized financial legal and tax services providers
world class infrastructure facilities and connectivity
primary hub and platform to access international business
high quality of life
political stability and liberal business environment
wide range of corporate vehicles and regimes
REQUIREMENTS AND STEPS
Step 1:
Obtain the consent letter from the Registrar of the foreign registry consenting the continuation and your registered agents
Step 2:
Submit the requirement documents and KYC information to RAK ICC Registry for review and approval
Step 3:
Obtain your certificate of continuation with 5 working days with NO publication required
WHO CHOSE RAK ICC FOR REDOM
Our Registered Agents and Business Partners have successfully competed many Redomiciliations of companies from various jurisdictions in the past few months
Name of Jurisdiction
Bahamas
Panama
Mauritius
Cyprus
British Virgin Islands

23. why RAK INTERNATIONAL CORPORATE CENTRE?
Well established corporate registry based in a strong recognized reputable jurisdiction operating in full compliance with international standards and best practices
Independent courts with common law judges for enforcement and matters of dispute. DIFC Wills are registered and enforced for asset protection and succession planning
Access to a large DTT network including a wide range of Bi-Lateral Investment Treaties. Three-year ( ) extension of the MoU between the UAE and the Organisation for Economic Cooperation and Development (OECD) has been signed in March 2019
Flexibility and no exclusion from dealing with other Off-Shore jurisdictions to create a more substantive product in need
Simple registration process with international corporate features and availability of various corporate structures
Residency Options; ZERO corporate and Individual Taxes
International and UAE Bank accounts available

24. THANK YOU
RAK International Corporate Centre - Government of Ras Al Khaimah
Ras Al Khaimah, United Arab Emirates,