RAK INTERNATIONAL CORPORATE CENTRE

THE REGISTRY OF CHOICE

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▪ Compliance with International Standards and reporting requirements

▪ Beneficial Ownership Regime

▪ New AML and CFT Policies

▪ The New Economic Substance Legislations

▪ Migration and Continuation Opportunities

▪ Abundant ecosystem of ample professionals, experts, offices and resources

THE NEW NORMAL– FLIGHT TO QUALITY

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WHY THE UNITED ARAB EMIRATES

▪ Strategic location▪ Compliant with international standards and reporting requirements ▪ Mature banking and legal system▪ Diversified and resilient economy with GDP /capita exceeding $40,000▪ Top ranks in ease of doing business and world government trust indexes▪ High-quality of life, diversified and business friendly environment

▪ Access to a broad range of UAE double tax treaty network▪ Low cost of doing business in Ras al Khaimah

▪ No taxation and no restrictions on capital and profit repatriation

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▪ The UAE is home to approximately 25,000 Russian citizens as well as a further 20,000Russian speakers from CIS (former Soviet Republics).

▪The annual bilateral trade between Russia and the UAE rose 21% last year to top more then $3 billion.

▪Key Russian companies in the UAE include: LUKOIL, Kaspersky, Rosatom, GazpromNeft, InterRAO, VTB Capital, Kamaz Int'l Trading, Metalloinvest Logistics DWC, Sovcomflot etc.

▪UAE national carriers now offer 56 weekly flights between UAE and Russia and Russiancitizens are granted visa on arrival.

▪The UAE is best positioned as Russia's gateway to the Middle East and Africa.

▪The number of Russian tourists travelling to the GCC was 933,000 in 2018 and expected toincrease to 2.1 million in 2023.

UAE & RUSSIA

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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

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OVER

30,000 COMPANIES WITH SHAREHOLDERS FROM OVER

160 COUNTRIES

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%

OVER 30,000INCORPORATIONS

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WHO ARE OUR REGISTERED AGENTS?

WE WORK THROUGH A NETWORK OF LOCAL AND GLOBAL CSP, LAW FIRMS AND ACCOUNTING AND TAX ADVISORS.

SOME LISTED BELOW:

International Corporate Services Providers

International Audit and Accounting Firms

International Law Firms

• Moore stephens

• Trident trust • Deloitte• Al tamimi & company

advocates & legal consultants

• Vistra group • Kpmg • Clyde&co

• Sovereign group • Pwc

• The legal group advocates and legal consultants

• Adam consulting • Bdo chartered

• Dentons and co.

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REGULATIONS

▪ Common law regulations with independent judicial system ▪ Private client solutions

▪ Fast, easy and cost-effective registration process ▪ Holding companies

▪ Migration & continuation from various jurisdictions ▪ Hybrid structures (IBC with onshore subsidiaries)

▪ Flexibility to share capital currency and approach to memorandum and article of association

▪ Segregated portfolio companies

▪ 100% foreign ownership and minimal reporting requirements▪ Wills registration

▪ International business companies (IBCs)▪ Transparency & compliance to the global standards regulations

STRUCTURES AND PRODUCTS

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Worldwide Investments &

Global Trade

Corporate Restructuring & Redomiciliations

Wealth Management

and Succession Planning

International Tax Planning

Structured Finance

Transactions

Securitizations and

Ring-Fencing Assets

Ownership of Real Estate

Properties & Assets

Holding Structures and

Special Purpose Vehicles

Estate Planning and Asset Protection

RAK ICC COMPANIES ARE BEST SUITED FOR

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1. COMPARISON OF STANDARD CORPORATE TAX RATES

Source: PwC Tax Summaries, EY, Deloitte, PKF

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% 0%13 0%10 0% 0% 0% 0%12 0%

DIVIDENDS 0% 0%13 0% 0% 0% 0% 3/15%9 0%

INTEREST INCOME 0% 0/35%11 12.5% 0% 0/8.25%4 17%5 3/15%7 10%

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2. COMPARISON OF INVESTMENT PROTECTION THROUGH BILATERAL INVESTMENT TREATIES (BITS)

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 force3) Investor protection offered under the Treaty on functioning of the European Union; No BITs in placeSource: Investment Policy Hub (UNCTAD)

U.A.E. MALTA CYPRUS BVI HONG KONG SINGAPORE MAURITIUS 1SEYCHELLES

U.K. Y Y Y3

No BITs with any countries

Y Y Y

GERMANY Y Y Y3Y Y Y

INDIA Y Y Y *Y

CHINA Y Y Y Y Y *Y

SOUTH AFRICA Y

PAKISTAN Y Y Y

SRI LANKA Y

SAUDI ARABIA Y

OMAN Y

TURKEY Y Y Y Y

EGYPT Y Y Y Y Y *Y

TANZANIA Y

ETHIOPIA 2*Y

KENYA *Y *Y

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1) *Y indicates the BIT has been signed but is not yet in force2) Investor protection offered under the Treaty on functioning of the European Union; No BITs in place

Source: Investment Policy Hub (UNCTAD)

U.A.E. MALTA CYPRUS BVI HONG KONG SINGAPORE MAURITIUS 1SEYCHELLES

FRANCE Y Y Y2

No BITs with any countries

Y Y Y Y

ITALY Y Y Y2Y

CANADA Y

BRAZIL

MEXICO *Y Y

COLOMBIA *Y *Y

ARGENTINA *Y

2. COMPARISON OF INVESTMENT PROTECTION THROUGH BILATERAL INVESTMENT TREATIES (BITS)

13Strategy& analysis, Tax Notes database of in-force treaties as at 31 August 2018, subject to change.

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 Africa

Algeria Asia (17) Bosnia and Herzegovina Portugal Africa 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 Europe

Mozambique Japan Georgia Switzerland Europe Antigua and Barbuda Guernsey

Senegal Korea (Rep.) Germany Ukraine Croatia Central America South America

Seychelles Malaysia Greece United Kingdom Ratified by the UAE (14) Costa Rica Peru

South Africa Maldives Hungary Caribbean Africa South America Oceania

Sudan Pakistan Ireland Barbados Benin Colombia Australia

Tunisia Philippines Italy North America Cameroon

Middle East Singapore Jersey Canada Equatorial Guinea

Jordan Sri Lanka Kosovo Central America Gambia

Lebanon Thailand Latvia Mexico Libya

Syria Turkey Liechtenstein Panama Nigeria

Yemen Vietnam Lithuania South America Rwanda

Central Asia Europe (41) Luxembourg Uruguay Middle East

Azerbaijan Albania Macedonia Venezuela Saudi Arabia

Kazakhstan Andorra Malta Oceania Caribbean

Kyrgyzstan Armenia Moldova Fiji St. Kitts and Nevis

Turkmenistan Austria Montenegro New Zealand Central America

Tajikistan Belarus Netherlands Belize

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EFFECTIVE WITHHOLDING TAX RATES ON DIVIDENDS DIFFER ACROSS JURISDICTIONS (1 OF 2)

HoldCo jurisdictions

U.A.E. MALTA CYPRUS BVI HONG KONG SINGAPORE MAURITIUS SEYCHELLES

U.K. 0% 0% 0% 0% 0% 0% 0% 15%

GERMANY 0% 0% 0% 0% 0% 0% 0% 15%

INDIA 0% 0% 0% 0% 0% 0% 0% 15%

CHINA 0% 0% 0% 0% 0% 0% 0% 5%

SOUTH AFRICA 0% 0% 0% 0% 0% 0% 0% 5/10%

U.A.E. MALTA CYPRUS BVI HONG KONG SINGAPORE MAURITIUS SEYCHELLES

PAKISTAN 10% 12.5% 12.5% 12.5% 10% 10/12.5% 10% 12.5%

SRI LANKA 10% 14% 14% 14% 14% 7.5/10% 10/15% 14%

SAUDI ARABIA 5% 5% 5% 5% 5% 5% 5% 5%

OMAN 10% 10% 10% 10% 10% 5% 0% 5%

TURKEY 10/12% 10/15% 15% 15% 15% 10/15% 15% 15%

EGYPT 0% 10% 10% 10% 10% 10% 5/10% 10%

TANZANIA 5/10% 5/10% 5/10% 5/10% 5/10% 5/10% 5/10% 5/10%

ETHIOPIA 10% 10% 5% 10% 10% 5% 10% 10%

KENYA 5% 10% 10% 10% 10% 10% 10% 10%

1) Domestic rate is 0% in principle; Source: PwC Tax Summaries, EY, Deloitte, SRC

DTT in place but non-treaty rate more advantageous DTT signed but not yet in force; non-treaty rate used No DTT in place, non-treaty rates used in practice

From HoldCo to UBO jurisdiction

From investment to HoldCojurisdiction

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EFFECTIVE WITHHOLDING TAX RATES ON DIVIDENDS DIFFER ACROSS JURISDICTIONS (2 OF 2)

1) Domestic rate is 0% in principle; Source: PwC Tax Summaries, EY, Deloitte, SRC

DTT in place but non-treaty rate more advantageous DTT signed but not yet in force; non-treaty rate used No DTT in place, non-treaty rates used in practice

From investment to HoldCojurisdiction

U.A.E. MALTA CYPRUS BVI HONG KONG SINGAPORE MAURITIUS SEYCHELLES

FRANCE 0% 0%/15% 10%/15% 21%/30% 10% 5%/15% 5%/15% 21%/30%

ITALY 5%/15% 15% 15% 26% 10% 10% 5%/15% 26%

CANADA 5%/15% 15% 15% 25% 5%/15% 15% 25% 25%

BRAZIL 0% 0% 0% 0% 0% 0% 0% 0%

MEXICO 0% 0% 10% 10% 0% 0% 10% 10%

COLOMBIA 5%/38.25% 5%/38.25% 5%/38.25% 5%/38.25% 5%/38.25% 5%/38.25% 5%/38.25% 5%/38.25%

ARGENTINA 7%/13% 7%/13% 7%/13% 7%/13% 7%/13% 7%/13% 7%/13% 7%/13%

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RE-DOMICILIATION OPPORTUNITIES TO MEET SUBSTANCE REQUIREMENTS

MAJOR ADVANTAGES

REASONS FOR REDOMICILIATION

Traditional Offshore jurisdictions are under pressure Maintain existing legal status

“offshore centres” facing extreme scrutiny internationally Preserve operational and banking history

Driving a shift from traditional offshore centres to high quality well-regulated mid-shore and onshore centres.

Access to common law courts

Companies are increasingly concerned with the reputational risk Meet Economic Substance Requirements

Whereas many jurisdictions will struggle to meet ESR, the UAE has an abundant ecosystem of professionals, experts, office and resources to meet the Economic Substance

Requirements.

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TRANSFER OF DOMICILE

• ESR requirements are achieved in a cost effective manner through Redomiciliation to RAK ICC.

• 100s of companies from many jurisdictions have successfully achieved this already and have benefited from continuing legal and banking structures.

• A proactive approach with clients is required to address reputational challenges as well as the challenges posed by ESR.

To meet the growing demand forre-domiciliation, we have created a new seamless process that can usually be completed within SEVEN DAYS.

BVI Companies and others have been proactively migrating to RAK ICC

BULK Redom Packages are available

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WHY RAK INTERNATIONAL CORPORATE CENTRE

1. Transparency & compliance to global standards & regulations2. Common law regulations with independent judicial system3. Fast, easy and cost-effective registration process4. Migration & continuation from various jurisdictions5. Flexibility to share capital currency and approach to Memorandum and article of association6. 100% foreign ownership and minimal reporting requirements7. Access to a large DTT network including a wide range of Bi-Lateral Investment Treaties8. Foreign Characters are permitted (i.e Chinese)9. International offices and vastly experienced staff 10. Residency Options; ZERO corporate and Individual Taxes

THANK YOURAK International Corporate Centre - Government of Ras Al Khaimah

Ras Al Khaimah, United Arab Emirates, info@rakicc.comwww.rakicc.com