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Tax-free repatriation

of profits

In Saint-Martin, the very favorable corporate tax regime is combined with a series of specific

provisions guaranteeing that companies can repatriate their profits tax-free.

1.

No withholding tax

on dividends

No withholding tax is applied by the

Collectivité

of Saint-

Martin on

dividends

distributed by a company esta-

blished in Saint-Martin to associates, legal entities or

persons, resident for tax purposes outside Saint-Martin.

2.

No withholding tax

on interest

No withholding tax is applied by the

Collectivité

of Saint-

Martin

on interest

paid by a company established in

Saint-Martin to associates,

legal entities or persons,

resident for tax purposes outside Saint-Martin.

3.

No withholding tax

on certain incomes paid

to beneficiaries that do not

have a permanent business

base in Saint-Martin

No withholding tax is applied to:

uu

sums paid as compensation for an activity carried

out in Saint-Martin for non-commercial professions

(lawyers, architects, auditors... );

uu

revenues received by inventors or from copyrights;

uu

revenues from industrial or commercial property and

similar rights;

uu

sums paid as compensation for services of any kind

provided in Saint-Martin (repair or maintenance of a

building located in Saint-Martin, technical incentives

in Saint-Martin, studies carried out in Saint-Martin... )

or used in Saint-Martin (rental of equipment effectively

used in Saint-Martin... );

uu

sums, including salaries, corresponding to artistic or

sporting services provided or used in Saint-Martin.

4.

No real tax barrier to the

invoicing of interest, royalties

or management fees

The amounts invoiced by a foreign company to its sub-

sidiary located in Saint-Martin are simply required to

be justified and in line with rates charged under normal

management conditions between independent companies.

The authorities of Saint-Martin may require evidence

that transfer prices are in line with actual market prices.

19

MARCH 2015 EDITION

DOING BUSINESS IN SAINT-MARTIN