Allow me to introduce to you today a structure that is gaining increasing prominence in the realm of international wealth planning and sophisticated asset protection: the Seychelles Private Interest Foundation, or PIF for short.

In light of the constantly evolving global economic and regulatory landscape, high-net-worth individuals and families are seeking robust and flexible solutions to secure their assets for the long term, efficiently manage succession, and optimize their tax situation within the bounds of the law. The Seychelles, a burgeoning and dynamic jurisdiction in the sphere of offshore financial services, has, with the introduction of the PIF in December 2009, created an instrument that, in many respects, sets new standards.

In the following exposition, I would like to elaborate on the essential features, advantages, and applications of this innovative structure in detail. In doing so, I will demonstrate how the PIF draws upon well-established concepts from other reputable jurisdictions while simultaneously integrating its own pioneering elements, making it a particularly attractive option for those clients for whom asset protection and tax minimization are paramount. My aim is to provide you with a comprehensive understanding of the potential of the Seychelles PIF and to illustrate in which scenarios this structure can provide significant added value to your individual wealth planning.

The Essence of the Seychelles Private Interest Foundation: A Foundation for Security and Flexibility

The Seychelles Private Interest Foundation can be viewed as a hybrid legal form that combines elements of a classic foundation with features of a trust. At its core, it is a legal entity sui generis established to hold assets for one or more beneficiaries or to pursue a specific purpose. However, what particularly distinguishes the PIF are the well-thought-out legal frameworks that offer a high degree of flexibility, discretion, and, above all, asset protection.

A central aspect of the PIF is the clear separation between the founder (the person who establishes the foundation and transfers assets), the council (the body that administers the foundation), and the beneficiaries (those who are ultimately intended to benefit from the assets). The law of the Seychelles explicitly states that neither the founder nor the beneficiaries have a direct ownership right to the assets contributed to the foundation. Rather, the foundation itself is the legal owner. This clear demarcation is of crucial importance for asset protection, as it prevents potential creditors of the founder or the beneficiaries from directly accessing the foundation’s assets.

Another notable advantage of the Seychelles PIF lies in the significant privacy it affords. In contrast to many other jurisdictions, neither the names of the founder nor those of the beneficiaries need to be filed in public registers. The establishment is effected through the simple submission of the foundation charter, which, in turn, does not need to contain details of the aforementioned individuals. Only the names of the council members are known internally but do not have to be publicly accessible. This discretion is invaluable for many of our clients, as they wish to shield their financial affairs from unwanted scrutiny.

The tax advantages of the Seychelles PIF are also significant. According to current legislation, foundations in the Seychelles are fully exempt from income or corporation tax. Similarly, no withholding taxes are levied on distributions, and no stamp duties are incurred. This tax neutrality makes the PIF an attractive instrument for international tax planning, particularly in conjunction with a holding structure.

The Dual Structure: A Bulwark Against Creditors and a Tool for Tax Deferral

As previously indicated, the Seychelles PIF often realizes its full potential when combined with an offshore company whose shares are held by the foundation. This dual structure proves to be extremely effective with regard to asset protection and potential tax deferral.

From an asset protection perspective, this constellation creates an additional layer of security. Since the foundation is the legal owner of the company shares, and neither the founder nor the beneficiaries have direct ownership rights, it becomes considerably more difficult for creditors to access the underlying assets of the company. Furthermore, the Seychelles Foundation Act contains some of the most stringent asset protection provisions ever formulated for a structure of this nature. For instance, it stipulates that any claims by creditors of the founder can only be asserted within a very short period of two years from the date of the transfer of ownership to the PIF. After this period, such claims are generally barred.

With regard to tax planning, the dual structure potentially allows for a legitimate deferral of taxation on offshore income. As long as no distributions are made by the foundation to the beneficiaries, domestic tax on the profits generated by the offshore company is generally not incurred (subject to the respective tax laws in the beneficiaries’ country of residence). Taxation in the country of residence may only become relevant at the time of an actual distribution by the foundation to the beneficiaries. This possibility of tax deferral can offer significant advantages for long-term wealth development and preservation.

However, it is essential to emphasize that the tax consequences must always be examined on a case-by-case basis and taking into account the specific circumstances of the beneficiary as well as the applicable tax laws in their country of residence. Comprehensive advice from an experienced tax advisor is indispensable in this context.

Flexibility and Efficiency: The Operational Advantages of the Seychelles PIF

In addition to the high level of asset protection and the potential tax benefits, the Seychelles PIF also offers remarkable operational flexibility and efficiency.

The establishment of a foundation in the Seychelles is a comparatively quick and straightforward process. Typically, a structure can be registered within a few hours of application, and name approval is also expedited. The annual government fees for maintaining the foundation are extremely modest at just US$200. Furthermore, no high minimum capital is required; an amount of only US$1 is sufficient, which only needs to be contributed after registration. This contrasts with other jurisdictions where significantly higher initial investments may be demanded.

The structuring and administration of a Seychelles PIF are also uncomplicated. Only one council member is required, which can be either a natural or a legal person. The founder themselves can also serve as a council member, as long as they are not the sole council member. In ongoing operations, the administrative requirements are minimal. There is no obligation to file an annual return, and the submission of audited financial statements is not required. Similarly, the need to hold annual general meetings is dispensed with. These streamlined administrative structures contribute to significant cost and time savings.

Succession Planning and Individual Structuring Options

Another important area of application for the Seychelles PIF lies in long-term succession planning. The ability to transfer the right to benefit from the foundation’s assets from one generation to the next, even outside the usual testamentary regulations, offers a high degree of flexibility in structuring wealth succession. The law of the Seychelles explicitly excludes the application of foreign laws regarding forced heirship, which allows for greater freedom of design.

The founder also has the option to reserve certain powers for themselves or others. These include, for example, the right to appoint or remove council members, to add or exclude beneficiaries, and to appoint or remove protectors. The appointment of a protector, who can veto certain decisions of the council, provides an additional layer of control and security. It is possible for the founder, a beneficiary, or a council member (with the exception of a sole council member or sole beneficiary) to also act as a protector.

The flexible application of the Seychelles PIF allows for the creation of structures that either have clear beneficiaries, or serve exclusively a specific purpose (without beneficiaries), or represent a combination of both. This versatility makes the PIF a suitable instrument for a wide range of individual needs and objectives.

Conclusion: A Forward-Thinking Instrument for the Global Elite

The Seychelles Private Interest Foundation presents itself as a highly developed and versatile structure that ideally meets the demands of a globally oriented and sophisticated clientele. The combination of robust asset protection, a high degree of privacy, potential tax advantages, operational efficiency, and flexible structuring options makes the PIF an attractive option for the long-term safeguarding and management of significant assets, as well as for well-considered succession planning.

With the introduction of this innovative instrument, the Seychelles has further solidified its position as a leading jurisdiction in the field of international wealth planning. In light of increasing global uncertainties and constantly changing regulatory frameworks, the Seychelles PIF offers a solid foundation for the preservation and protection of assets across generations.

It is my pleasure to have brought this remarkable structure closer to your understanding. Should you require further information or wish to receive individual advice regarding the application possibilities of a Seychelles PIF for your specific needs, I am, of course, at your disposal.

---

We’ve helped hundreds of people move their businesses overseas, legally reduce their taxes, and become dual citizens. We are focused on high-net-worth individuals and their families as well as corporations wishing to invest their offshore companies or even secure their wealth in offshore financial centers around the world. We will help you to find the best solution for setting up an offshore or onshore company. Another special area of our full-service consulting is the investment opportunity and solution in Europe, especially in the Balkans, Africa, Asia, UAE, the Caribbean and the Pacific.

If you are looking for it, please feel free to contact us. We create a holistic plan that serves your purpose.

The TCME Group Worldwide as well its partner in Vanuatu are accredited, licensed and authorized agents and facilitators of the Government of Vanuatu for the citizenship programs of the VDSP and the CIIP in Vanuatu.

GCI UNIT Worldwide by TCME Worldwide Group, designs and implements customized, holistic strategies for successful investors and entrepreneurs to legally reduce their tax bills, diversify and protect their wealth, invest abroad, gain a second citizenship and live a freer life worldwide to lead.

YOUR CHANCE FOR A BETTER LIVE

TCME Worldwide Group firm is a leading professional International Business Investment and Advisory Firm for Foreign Economic Relations. Our range of services includes:

• Offshore and Onshore Company Formation,
• international Business & Management
• Citizenship & Residency (Advice on residency and citizenship by investment programs, VIP citizenship programs in cooperation with more than 70 countries)
• Investments & Corporate Financing
• Advisory for Foreign Economic Relationship
• Diplomatic Consultancy & Public Affairs

If you would like to discuss your internationalization and diversification plans, book a consulting session* or email us under:  [email protected]

*A counseling session is a conversation about your portfolio and goals. It does not constitute legal, financial, tax or investment advice.

TCME Worldwide Group – Global Investments –
Level 33, Ilham Tower, 8 Jalan Binjai,
Kuala Lumpur 50450, Malaysia

www.tcme.company
www.citizenship-news.com

International Phone: +66 99091 8357 (also for BOTIM, Signal, Viber, Telegram)
Malaysia Phone: +603 2169 7057
Montenegro Phone: +382 69 150 130 (WhatsApp)

Telegram https://t.me/passport_Vanuatu

Telegram https://t.me/passport_news

[email protected]