Mobile phone tycoon John Caudwell, owner of Caudwell Group, has denied rumours
that he is to re-register the firm in Madeira to cut costs as the company undergoes
a major management shake-up.
The rumours surfaced after the departure of three key managers from his Manchester
call centre which sells fixed line telephone services under the brandname Homecall.
Citing a "lack of focus" in the group which had subsequently led to
"operational difficulties," managing director Keith Basnett, financial
director Michael Hughes and commercial director Richard Raper all quit within
24 hours of one another. Whether they jumped or were pushed is not entirely
clear. However, Caudwell, who reportedly has a reputation for his no-nonsense management
approach, denied sacking the men.
According to the Manchester Evening News, there had also been heated boardroom
discussions over a plan to re-register the company in Madeira as part of a cost-cutting
drive. However, Caudwell has rebuffed the suggestion, telling the MEN that:
"We are not doing anything over Madeira or anywhere else at the moment."
Madeira is part of Portugal and is fully integrated into the European Union.
However, a number of special local regimes which are accepted by the EU combine
to make Madeira a particularly advantageous location for many types of company
with business activities in the EU.
The rate of corporate income tax in Portugal (and Madeira) effective from 2004
is 25%, plus a municipal surcharge of 10%, giving an effective rate of 27.5%.
However, most offshore activity in Madeira takes place in and around the International
Business Centre (IBC), which comprises the Free Trade Zone, and its associated services,
together with financial institutions and the Shipping Registry.
Companies in the IBC licensed before 2001 receive tax exemption until 2011 on revenues
derived from other companies within the various sectors of the International Business
Centre (ie manufacturing, services etc), and on revenue derived from non-residents
on Portuguese territory. Under the Tax Reform Act of 2000, which was finally approved by the EU in late 2002, companies which register under the new regime are able to enjoy a reduced rate of tax of 1% in 2003-2004, 2% in 2005-2006 and 3% in 2007-2011 (instead of the normal rate, currently 25%).
Holding Companies and Mixed Holding Companies in Madeira receive a 95% deduction
from taxable income received from their holdings, so that they are taxed at 36%
of 5% of income, equals 1.8%.
If a Holding Company is established under Free Trade Zone Legislation then income
received from its holdings in the EU is taxable but income from non-EU sources
is exempt from tax. Dividends distributed by such companies to non-resident shareholders
are free of withholding tax.
Income earned by a Mixed Holding Company licensed under the Free Trade Zone
Legislation from trading activities (other than through the holding of shares)
is exempt from corporation tax until the year 2011. Capital gains tax of 36%
is payable by a Madeira Holding Company on the profitable sale of shares in
a company in which it has a participating shareholding.
Furthermore, Portugal has nearly 40 double tax treaties, and these can be used
alongside the International Business Centre to obtain a very low tax burden
for many types of trading and commercial activity.