This type of company can be found in the most highly utilised offshore jurisdictions like Mauritius and Gibraltar. An important advantage of the hybrid company is that it can be used as a trust, especially where there is no trust law or where offshore trusts are not recognised.

The hybrid company is often used in jurisdictions where CFC-legislation applies to participants of offshore assets. The hybrid company avoids this legislation by establishing a liability, rather then an asset.
The hybrid company can serve a similar purpose in countries which enforced reporting requirements on trusts, but are not yet known with the hybrid company.

The hybrid company consists of 2 classes of members, shareholders and guarantee members.
The shareholders can hold the shares, whereas the guarantee members guarantee to meet the company’s liability up to a certain fixed amount. By separating the economic interest from control, the hybrid company can function as a quasi-trust.
Although the company is commonly used as a charitable organisation, it can be created so that the shareholding members act as trustees, and the guarantee members take benefit like beneficiaries.

The hybrid company can be used for various tax and asset planning strategies. If you are interested in this entity, or you would like to know if this entity could be useful for your asset or tax planning please contact us.

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Inco Trust provides hybrid companies in the following jurisdictions:

British Virgin Islands, Isle of Man, and Gibraltar.