Annex
United Kingdom
| Note: the numbering of the companies follows the numbering of the annex of the decision to extend proceedings. For the sake of completeness, the table includes the five contested tax rulings with numbers 83, 84, 139, 140 and 144. | |||
| Company Name | Granting Date | Description of the activities | Classification of Ruling (in light of Section 8.2.1) |
|---|---|---|---|
| 1. KaiRo Management Limited | 7.1.2011 | Services, management consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 2. Thurlestone Shipping (Overseas) Limited | 10.1.2011 | Services, shipping intermediary | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 3. Mina Corp Limited | 10.1.2011 | Trade, sale of petroleum products | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 4. Red Star Enterprises Limited | 10.1.2011 | Trade, sale of petroleum products | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 5. BO (Middle East) Limited | 12.1.2011 | Trade, importation of furniture | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 6. THE One (Middle East) Limited | 12.1.2011 | Trade, importation of furniture | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 7. THE One Retail Network (International) Limited | 12.1.2011 | Holding company, licensing intellectual property | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 8. THE One Music Limited | 12.1.2011 | Trade, manufacture and sale of CDs | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 9. Prospective Company | 12.1.2011 | Holding company, licensing intellectual property | Company was not incorporated, activities did not materialise or the company was dormant |
| 10. Link Holdings (Gibraltar) Limited | 14.1.2011 | Trade, income from rents | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 11. European Mail Union Limited | 28.1.2011 | Trade, provision of mail forwarding | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 12. Ansellia Aviation Limited | 31.1.2011 | Holding of assets, property (aircraft) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 13. Prospective Company | 4.2.2011 | Beneficiary in a trust | Company was not incorporated, activities did not materialise or the company was dormant |
| 14. Prospective Company | 7.2.2011 | Provision of loan(s) | Company was not incorporated, activities did not materialise or the company was dormant |
| 15. Zartello Limited | 7.2.2011 | Trade, marketing services | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 16. Gol International Limited | 10.2.2011 | Trade, sports agent | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 17. Graf Von Bismark and Associated Limited | 21.2.2011 | Trade, provision of asset managers | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 18. Medifour Limited | 25.2.2011 | Trade, sale of medical products | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 19. Current Technology (Europe) Limited | 25.2.2011 | Trade, marketing | Company was not incorporated, activities did not materialise or the company was dormant |
| 20. Corporate Consultants Limited | 25.2.2011 | Services, consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 21. Alphasol Limited | 25.2.2011 | Services, consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 22. Akasha Charters Limited | 25.2.2011 | Trade, yacht chartering | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 23. Osato Industries Limited | 28.2.2011 | Services, consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 24. Gambit Management Services Limited | 1.3.2011 | Holding of property and consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 25. Greatheart Underwriting Limited | 4.3.2011 | Investment holding company | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 26. UNILOG, United Logistics & Shipping Operators Limited | 9.3.2011 | Trade, management of shipping line | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 27. Continental Maritime Limited | 15.3.2011 | Provision of loan(s) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 28. Baby Basics Limited | 15.3.2011 | Trade, marketing | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 29. Baby Basics (Iberia) Limited | 15.3.2011 | Trade, marketing and sales, training | Company was not incorporated, activities did not materialise or the company was dormant |
| 30. Baby Basics (International) Limited | 15.3.2011 | Trade, distribution of products | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 31. Baby Basics (Asia) Limited | 15.3.2011 | Trade, marketing and sales, training | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 32. Family Roots Limited | 15.3.2011 | Trade, marketing | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 33. Western Mediterranean Holdings Limited | 16.3.2011 | Investment holding company | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 34. M. Benady & Company (Gibraltar) Limited | 16.3.2011 | Trade, management services | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 35. Prime Ideas Limited | 18.3.2011 | Holding intellectual property rights | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 36. Hattrick Limited | 21.3.2011 | Services, consultancy and advisory | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 37. Tubingen Limited | 22.3.2011 | Asset holding company, motor yacht | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 38. Channel Energy (Eire) Limited | 24.3.2011 | Trade, storage and handling of petroleum | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 39. Crane Trading Corporation Limited | 24.3.2011 | Trade, motors | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 40. Europe Income Real Estate Limited | 25.3.2011 | Provision of loan(s) | Company was not incorporated, activities did not materialise or the company was dormant |
| 41. IMAAG Limited | 25.3.2011 | Services, consultancy and advisory | Company was not incorporated, activities did not materialise or the company was dormant |
| 42. Prospective Company | 28.3.2011 | Trade, marketing services | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 43. Jonsden Properties Limited | 28.3.2011 | Trade, marketing services | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 44. Ellise Trading Group Limited | 28.3.2011 | Holding, intellectual property | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 45. Kamakura Investments Limited | 29.3.2011 | Investment holding | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 46. Prospective Company | 1.4.2011 | Trade, advertising | Company was not incorporated, activities did not materialise or the company was dormant |
| 47. Roxbury Limited | 1.4.2011 | Holding of patents and trademarks | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 48. Roger Bullivant Holdings Limited | 1.4.2011 | Group Holding | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 49. Horizon Ventures Limited | 1.4.2011 | Services, consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 50. Nidham Holdings Limited | 1.4.2011 | Services, consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 51. AMD Limited | 1.4.2011 | Trade, sale of agricultural products | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 52. Cookstown Properties Limited | 5.4.2011 | Holding, company shares | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 53. Burlington English Limited | 7.4.2011 | Services, consultancy and advisory | Company was not incorporated, activities did not materialise or the company was dormant |
| 54. Burlington Marketing Limited | 7.4.2011 | Services, consultancy and advisory | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 55. Burlington English Limited | 11.4.2011 | Services, consultancy and advisory | Company was not incorporated, activities did not materialise or the company was dormant |
| 56. Burlington Marketing Limited | 11.4.2011 | Services, consultancy and advisory | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 57. Eastcheap Trading Corporation Limited | 14.4.2011 | Provision of loan(s) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 58. Horizon Ventures Limited | 14.4.2011 | Services, consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 59. Keystone Shipping Limited | 4.5.2011 | Trade, bareboat chartering | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 60. World Rugby League (Europe) Limited | 6.5.2011 | Trade, marketing services | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 61. World Rugby League Limited | 6.5.2011 | Trade, marketing services | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 62. Lobric Properties Limited | 6.5.2011 | Trade, sale of agricultural products | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 63. Bushman Limited | 6.5.2011 | Services, consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 64. Key Retail Technologies Limited | 9.5.2011 | Services, management and consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 65. Kinsman Trustees Limited | 11.5.2011 | Services, provision of trustees | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 66. Amicus Trustees Limited | 11.5.2011 | Services, provision of trustees | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 67. Benamara Limited | 11.5.2011 | Investment holding | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 68. Halstead Investments Limited | 11.5.2011 | Investment holding | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 69. Nightingale Investments Limited | 11.5.2011 | Trade, supply of oil and gas equipment | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 70. JST (International) Company Limited | 11.5.2011 | Services, consultancy and advisory | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 71. The Consultants Limited | 11.5.2011 | Services, consultancy and advisory | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 72. Birchall Properties Limited | 17.5.2011 | Provision of loan(s) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 73. Cookstown Properties Limited | 19.5.2011 | Property and investments holding | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 74. Paramount Healthcare Consulting Limited | 20.5.2011 | Services, consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 75. Swerford Holdings Limited | 20.5.2011 | Trade, gaming | Ruling related to personal income tax and does not involve a company subject to corporate income tax |
| 76. Orios Limited | 23.5.2011 | Trade, online flower and gift retailer | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 77. Bushman Limited | 23.5.2011 | Services, consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 78. Nautilus Limited | 1.6.2011 | Asset holding, motor yacht | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 79. Salamba Shipping Limited | 1.6.2011 | Asset holding, motor yacht | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 80. Repset Limited | 1.6.2011 | Group Holding | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 81. McWane (Gibraltar) Holdings Limited | 2.6.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 82. McWane (Gibraltar) Limited | 2.6.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 83. Heidrick and Struggles (Gibraltar) Holdings Limited. | 2.6.2011 | Provision of loan(s) | Contested ruling |
| 84. Heidrick and Struggles (Gibraltar) Limited. Limited, GibCo2) | 2.6.2011 | Provision of loan(s) | Contested ruling |
| 85. Walstead Limited | 8.6.2011 | Trade, marketing, sales and research | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 86. Meritas (Gibraltar) Holdings Limited | 8.6.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 87. Perpetual Systems Limited | 9.6.2011 | Trade in Gibraltar | Ruling related to personal income tax and does not involve a company subject to corporate income tax |
| 88. Loksys (International) Limited | 15.6.2011 | Trade in Gibraltar | Ruling related to personal income tax and does not involve a company subject to corporate income tax |
| 89. Lawnsvale Investments Limited | 16.6.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 90. Oilcom Agency Limited | 24.6.2011 | Trade, buying and selling of clothing | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 91. CT Marketing Limited | 30.6.2011 | Services, consultancy and marketing | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 92. Navigia Limited | 5.7.2011 | Services, consultancy | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 93. Ocean Pride Shipping Co. Limited | 5.7.2011 | Asset holding, motor yacht | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 94. Equilibrium Management Limited | 11.7.2011 | Provision of loan(s) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 95. Taylan Limited | 11.7.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 96. Prospective Company | 12.7.2011 | Trade, currency exchange | Company was not incorporated, activities did not materialise or the company was dormant |
| 97. Galva Investments Limited | 13.7.2011 | Investment holding | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 98. Uniphos Limited | 13.7.2011 | Services, consultancy and marketing | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 99. Prospective Company (Advisory Limited) | 14.7.2011 | Provision of loan(s) | Company was not incorporated, activities did not materialise or the company was dormant |
| 100. Prospective company | 22.7.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 101. Prospective company | 5.8.2011 | Trade, marketing | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 102. Hastings Insurance Group Limited | 11.8.2011 | Group Holding | Ruling related to personal income tax and does not involve a company subject to corporate income tax |
| 103. Patron Capital G.P. III Limited | 17.8.2011 | Provision of loan(s) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 104. Vantini Spur Limited | 14.9.2011 | Holding intellectual property | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 105. Tubman (International) Limited | 14.9.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 106. Tubman (Holdings) Limited | 14.9.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 107. Broadstreet (Gibraltar) Limited | 30.9.2011 | Services, consultancy and loan interest | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 108. Biomet (International) Limited | 6.10.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 109. Biomet (Gibraltar) Holdings Limited | 6.10.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 110. Biomet Inc | 6.10.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 111. Biomet S.a.r.l | 6.10.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 112. Waterside (International) Limited | 8.11.2011 | Services, management advisory | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 113. Prospective Company International Law Firm) | 16.11.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 114. Infor (Gibraltar) Limited | 22.11.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 115. Miller International Limited | 24.11.2011 | Trade, sale of earth moving products | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 116. Tipico Services Limited | 29.11.2011 | Services, administrative support | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 117. Select Sports Management Limited | 16.12.2011 | Services, consultancy football agent | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 118. Allabroad Limited | 16.12.2011 | Trade, sailing tuition and yacht charters | Effectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar |
| 119. Prospective Company | 16.12.2011 | Services, administrative support | Company was not incorporated, activities did not materialise or the company was dormant |
| 120. Delphi Automotive Services (Gibraltar) Limited | 20.12.2011 | Subsidiary company | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 121. 8F Leasing (Gibraltar) Limited | 22.12.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 122. 8F Leasing S.A. | 22.12.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 123. 8F leasing (Bermuda) Limited | 22.12.2011 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 124. Scan Truck & Trailer Rental Limited | 3.1.2012 | Trade, truck and trailer rental | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 125. Matterhorn Holdings Limited | 16.1.2012 | Trade, Sale of IT materials | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 126. 8F Leasing (Gibraltar) Limited | 3.2.2012 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 127. 8F Leasing (Bermuda) Limited | 3.2.2012 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 128. 8F Leasing S.A. | 3.2.2012 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 129. 8F Leasing (Gibraltar) Limited | 20.2.2012 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 130. 8F Leasing (Bermuda) Limited | 20.2.2012 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 131. 8F Leasing S.A. | 20.2.2012 | Provision of loan(s) | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 132. Zaida Company Limited | 2.3.2012 | Trade, fees and commissions on payments | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 133. Rowan Gorilla V (Gibraltar) Limited | 29.3.2012 | Trade, oil well drilling rig (charter) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 134. Rowan Gorilla VII (Gibraltar) Limited | 29.3.2012 | Trade, oil well drilling rig (charter) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 135. Rowan Cayman Limited | 29.3.2012 | Trade, oil well drilling rig (charter) | Company was not incorporated, activities did not materialise or the company was dormant |
| 136. Rowan Drilling (Gibraltar) Limited | 29.3.2012 | Trade, oil well drilling rig (charter) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 137. Rowan Drilling Norway AS | 29.3.2012 | Trade, oil well drilling rig (charter) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 138. Kiluya Employment Management Limited | 3.5.2012 | Services, provision of engineers | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 139. Ash (Gibraltar) One Limited | 8.5.2012 | Subsidiary of chemical company | Contested ruling |
| 140. Ash (Gibraltar) Two Limited | 8.5.2012 | Subsidiary of chemical company | Contested ruling |
| 141. Prospective Company | 12.6.2012 | Holding intellectual property | Company was not incorporated, activities did not materialise or the company was dormant |
| 142. Partner Invest Limited | 21.8.2012 | Trade, company incorporation | Effectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar |
| 143. Partner Invest Limited | 21.8.2012 | Trade, company incorporation | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 144. MJN Holdings (Gibraltar) Limited | 11.9.2012 | Subsidiary in group structure | Contested ruling |
| 145. Fidux Trust Company Limited | 9.10.2012 | Trade, provision of trust services | Effectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar |
| 146. OED Limited | 4.1.2013 | Trade, software development | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 147. Sunbreeze Limited | 12.2.2013 | Trade, online broker | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 148. Prospective Company | 12.4.2013 | Holding intellectual property | Company was not incorporated, activities did not materialise or the company was dormant |
| 149. Promo 6000 International Limited | 22.4.2013 | Trade, marketing and advertising | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 150. Visavi 5x5 Limited | 22.4.2013 | Trade, website portals | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 151. Visavi Activities Limited | 22.4.2013 | Holding company shares | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 152. Visavi Spins Limited | 22.4.2013 | Trade, website portals | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 153. Visavi Portals Limited | 22.4.2013 | Trade, website portals | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 154. Prospective Company | 10.5.2013 | Holding intellectual property | Company was not incorporated, activities did not materialise or the company was dormant |
| 155. Scanlan Worldwide Limited | 21.5.2013 | Trade, buying, importing and exporting | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 156. Rebecca (Holdings) Limited | 10.6.2013 | Provision of loan(s) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 157. IAPA (Global) Limited | 24.6.2013 | Trade, master policy insurance cover | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 158. Collinson Group (Trademarks) Limited | 24.6.2013 | Holding intellectual property | Passive income exemption. Situation regularised after legislative changes or activities ceased. |
| 159. Rebecca (Holdings) Limited | 28.6.2013 | Provision of loan(s) | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 160. Innophus (Gibraltar) Limited | 2.8.2013 | Trade, industrial manufacturing | Company was not incorporated, activities did not materialise or the company was dormant |
| 161. Stabalis Limited | 22.11.2013 | Services, provision of consulting intra-group services | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 162. J Domains Limited | 20.12.2013 | Services, management of domain sales | Application of territoriality principle. No income accrued in or derived from Gibraltar. |
| 163. Prospective Company | 23.12.2013 | Trade, supply of merchandise | Company was not incorporated, activities did not materialise or the company was dormant |
| 164. Potential immigrant | 23.12.2013 | Employee | Ruling related to personal income tax and does not involve a company subject to corporate income tax |
| 165. British Virgin Islands Company | 23.12.2013 | Trade, provision of digital products such as online training courses | Effectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar |