The Attribution Regime (ARI) for Individuals will be abolished with effect from 6th April 2012. The ARI ensured that Isle of Man resident shareholders did not roll up profits in an Isle of Man company tax free.
The abolition of the ARI means that Isle of Man resident shareholders of Isle of Man companies may be able to roll up profits tax free in a company until such time as a distribution is made. The use of a company structure with the ability to roll up profits tax free for Island residents would appear to be a very attractive proposition, but perhaps unfair to the majority of taxpayers unable so to do.