• Your staff has persuaded me to lodge the insurance claim. I am very grateful for your assistance.

    Mrs. MM, Milnerton, South Africa

  • Compared to the claims settlement of German insurance companies, it was amazing to see how fast you settled my claim. Thanks a million!

    Mr. H., Constantia, Cape Town

  • We have built a very good and pleasant business relationship over the years. A very recommendable company for all insurance needs. I am looking forward working with you.

    Mr. JS, Cape Town, South Africa.
  • I have never experienced such an efficient handling of a claim. We are very happy and will recommend your services.

    Mrs. K, Somerset West, South Africa.
  • Congratulations to your immigration guide. We have not found anything close that is so informative and hands-on.

    Mr. & Mrs. AC, Munich, Germany

  • Just to let you know that we finally received our 6 year extension to our business permit. Once again, many thanks for your help and advice in this matter.

    Mr. K., Camps Bay, Cape Town

  • We have mandated you to organize our immigration, off-shore tax planning and insurance matters. We are highly impressed with the professional service and have recommended your company to friends.

    Mr. WK, Somerset West, South Africa

  • A very good and highly interesting newsletter. Your publication leaves anything else in the dark.

    Mr. JK, Duesseldorf, Germany

  • Excellent service – thank you very much!

    Mr. KZ, Contantia, South Africa.
  • Thanks for your newsletter, which we find very interesting and informative.

    PH, Loenberg, Germany

Swiss Banking South Africa
Off-shore Private Banking Insurance Print

Insurance Wrapper Portfolio

The publication by the South African tax authorities (SARS) can be found on their website (www.sars.gov.za ). The Commissioner issued the ruling by means of an Advanced Tax Ruling (ATR).

What is an off-shore private banking wrapper?

The concept stands for the incorporation of your off-shore assets in a tax-compliant structure that takes care of your investment, tax and estate planning strategy in one single tailor-made solution.

The wrapper was launched in South Africa in 2006 for SA tax residents with assets outside South Africa.

What are the tax implications?

The introduction of the principle of the worldwide tax system in South Africa, combined with a new definition of a tax resident, has given many off-shore investors a heavy tax burden and a complicated tax return.

In South Africa, the transfer of assets to the wrapper will result in a "swap" from any income tax (highest marginal rate 40%) to a capital gains tax, CGT, which effective maximum rate is 10%. Due to the calculation formula issued by SARS for the determination of CGT on foreign policies, most investors do not pay any taxes.

There is no taxes payable on interest, dividends and capital growth etc. as long as the assets remain in the structure. CGT will only apply upon withdrawal or termination of the concept.

Beneficiaries in the event of your death will also benefit from tax concessions when it comes to the payout of the insurance contract.

Please note that The "Insurance Wrapper" can give the investor tax advantages not only in South Africa, but in other tax jurisdictions as well.

Individuals that are liable for taxes in the U.S.A. can also use this structure. They can now invest in the US stock and bond markets without having to disclose their identity towards the US authorities.

Which institutions are involved?

The insurance platform is provided by an insurance company in Liechtenstein. The custodian banks are currently UBS, Credit Suisse, Julius Bär and Luzerner Kantonalbank. Other banks can be incorporated, but need to be domiciled in Switzerland.

In order to retain the above tax concessions, you need an asset manager, either at your custodian bank or you can appoint an independent advisor.

We have carefully selected first class partners for our network that are able to offer our clients superior knowledge and service.

What is the risk involved - how secure are my assets?

Your assets are legally protected and cannot be touched by creditors, plaintiffs, insolvency, governments etc.

Further, the following security aspects have been taken care of:

  • Insurance company: Your assets are segregated from insurer's balance sheet. The default of the insurance company has no affect on your assets.
  • Custodian bank: They do not own your assets either and your funds remain in the name of your policy with the insurer.
  • Asset manager: He/she has a restricted power of attorney and cannot withdraw or transfer any of your assets. Only client instructions are accepted.

The only risk remaining is the investment risk - you determine your own investment strategy together with your asset manager.

How does the wrapper work in practice?

In a first step, your personal circumstances details (tax residence, estate planning, investment strategy etc.) are analyzed with utmost confidentiality by our partners in Switzerland. A proposal is then forwarded to you.

If you accept the proposal, the insurance company issues the policy and an account at one of the custodian banks is opened. Existing assets such as shares, bonds, cash, mutual funds, private equity etc. are then transferred to the bank. THERE IS NO NEED TO SELL EXISTING ASSETS, as they are held within the insurance policy in your name.

Who could benefit from the structure?

The following categories of investors can benefit:

  • Investors who are liable for tax either in South Africa, Germany, UK, United States, Spain, Scandinavia or Italy.
  • Investors who would like to minimize their worldwide tax liability, being tax residents in multiple tax jurisdictions.
  • South African investors with funds abroad or planning to make use of their offshore allowance.
  • SA tax residents that would not only want to simplify their tax returns but also prefer paying 10% capital gains tax vs. 40% income tax.
  • Investors with succession and international tax planning needs, because beneficiaries of the estate are situated in different tax jurisdictions.
  • Persons thinking of immigrating to South Africa: They should arrange their financial matters before becoming a tax resident in South Africa.

What other aspects should I consider?

  • Your assets are held safely and confidentially: The Swiss Banking and Insurance Secrecy Law apply.
  • The structure is very flexible with unrestricted access: There is no minimum contract term, regular or ad-hoc withdrawals can be structured free of tax (and charges) and there are no surrender penalties.
  • Beneficiary nominations are flexible and can be changed at any time.
  • Compared to traditional structures such as Trusts, „Stiftungen" and off-shore companies, the insurance wrapper is easier to understand, fully tax compliant with you tax residence and cost efficient.
  • Regular reports are created about your investment performance.
  • The wrapper is approved by SARS. There are similar structures being offered in the market, but none of them has got certainty of compliance and cannot be guaranteed to be tax efficient.
  • There is no need to have a separate will in Switzerland, as the policy makes provsion for direct beneficiary nominations.

What are the costs involved?

The costs involved are all-inclusive and are transparently priced. There are no hidden costs and commissions.

The costs depend on the investment amount. There is an initial fee to set up the structure (analysis and recommendation, opening of bank account, transfer of assets and issuing of policy), as well as an ongoing fee. The following components apply:

  • Fee charged by the insurer
  • Asset management fee: The fee can either be a fixed fee p.a. or a performance fee with a "high-water mark".
  • Bank charges: The bank fee is a flat fee which is extremely low. Any commissions received by the bank are refunded to the client. Therefore, you trade at net costs.

Please note that the minimum investment amount is Swiss Francs (CHF) 250'000.

Where can I obtain more information?

You can contact Mr. Hug ( This e-mail address is being protected from spambots. You need JavaScript enabled to view it ) if you would like to set up a confidential meeting.

 

Contact Our Team


Phone: +27 (0)21 551 3331
Fax: +27 (0)21 551 8061
Email: info@swissfin.co.za

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