Im on an EU passport, and a few years ago I moved myself to Gibraltar from UK, setting up a GibCo. I was operating an online business in the medical industry, was starting to see growth and the prospect of charging the same monthly fee without having to pay VAT on it was attractive (as medical professionals being exempt, what they pay is what they pay as they are unable to claim back VAT).
Unfortunately from a personal perspective, Gibraktar didn’t work out personally, so I moved to Spain and all of a sudden due to the Spain/Gib treaty (yes I’m aware I should have researched this) I encountered significant challenges keeping the GibCo as a Gib tax resident (purely by being 100% shareholder, even with an office in Gib, employees, local director, meticulous tracking of commute and documentation of no business activity etc in Spain).
This led to me deciding to move out of Spain to protect the tax residency of the company, and I took the opportunity to fund a jurisdiction which would be beneficial for me personally.
So, my setup is
Cyprus Holding Company with myself as a director and 100% owner , with an office lease, and local bank account. I have registered as non dom , having met all the criteria and am in Cyprus more than 183 days per year, ensuring no other jurisdiction can claim tax residency.
The Cyprus company owns the Gib Co, which still maintains its presence in Gib with the aforementioned office, local director and employees.
Due to the nature of the business, none of our income is accrued and derived in Gib, and thus the company pays 0% Corp Tax, verified by local gib lawyers.
The Cyprus holding company invoices the Gib Co a conservative amount per month for consulting (of which I do actual work in Cyprus in the office). This is not charged with VAT due to Gibraltar being outside the EU. Then the profits of the GibCo flow up to the Cyprus holding company as dividends, which get paid out to myself as dividends, paying the capped Gesy contributions.
Although this has been a lot of work to research and setup, I still have concerns I’m missing something due to an extremely limited tax liability overall (simply the Gesy contributions, no VAT or corp tax).
Have I missed something glaringly obvious or is this a legitimate setup?
Unfortunately from a personal perspective, Gibraktar didn’t work out personally, so I moved to Spain and all of a sudden due to the Spain/Gib treaty (yes I’m aware I should have researched this) I encountered significant challenges keeping the GibCo as a Gib tax resident (purely by being 100% shareholder, even with an office in Gib, employees, local director, meticulous tracking of commute and documentation of no business activity etc in Spain).
This led to me deciding to move out of Spain to protect the tax residency of the company, and I took the opportunity to fund a jurisdiction which would be beneficial for me personally.
So, my setup is
Cyprus Holding Company with myself as a director and 100% owner , with an office lease, and local bank account. I have registered as non dom , having met all the criteria and am in Cyprus more than 183 days per year, ensuring no other jurisdiction can claim tax residency.
The Cyprus company owns the Gib Co, which still maintains its presence in Gib with the aforementioned office, local director and employees.
Due to the nature of the business, none of our income is accrued and derived in Gib, and thus the company pays 0% Corp Tax, verified by local gib lawyers.
The Cyprus holding company invoices the Gib Co a conservative amount per month for consulting (of which I do actual work in Cyprus in the office). This is not charged with VAT due to Gibraltar being outside the EU. Then the profits of the GibCo flow up to the Cyprus holding company as dividends, which get paid out to myself as dividends, paying the capped Gesy contributions.
Although this has been a lot of work to research and setup, I still have concerns I’m missing something due to an extremely limited tax liability overall (simply the Gesy contributions, no VAT or corp tax).
Have I missed something glaringly obvious or is this a legitimate setup?
