Companies structure

euroartdesign

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Dec 29, 2019
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I am European citizent.

What do you think about the following configuration:

  1. Romanian citizent makes Cyprus company
  2. Then the Cyprus comapny receives 200k payments (to its EMI's account) from different Romanian companies (invoices for sales or advertising)
  3. Other or same Romanian citizent makes Seychelles or Marshal company with bank account or EMI and receives 190k from the Cyprus company to reduce the tax of the Cyprus company
 
I am asking here in the mentor group, as i am sure there are admins & gurus that can give best comment/advice 🙂
The purpose of the structure is tax optimisation...
 
I don't think it would work. Cyprus shares tax information with Romanian and your tax office would see it as a fraud

Check CFC rules in your company, but looks like a bad idea

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This sounds like a huge fraud setup. I don't care but if you want to do that it has to be based on darks otherwise there is no way around CRS and other reporting standards!
 
GiGoGo said:
I don't think it would work. Cyprus shares tax information with Romanian and your tax office would see it as a fraud

Check CFC rules in your company, but looks like a bad idea
Click to expand...
Why you think they will see it as fraud? All the Romanian companies that will pay to the cyprus company are different with different owners and also the owners of the cyprus company and marshall company are different.
If you still dont like this structure please recommend me another one?
 
Because you are Rumanian citizen working on Rumanian soil. Can work for some time, but one day the tax office can have a look on that and decide that you are doing that to dodge taxes

I would recommend moving your a*s from Rumania or try a US LLC

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Expat in Hong Kong - There are two ways to conquer and enslave a nation. One is by the sword. The other is by debt. - John Adams
 
GiGoGo said:
Because you are Rumanian citizen working on Rumanian soil. Can work for some time, but one day the tax office can have a look on that and decide that you are doing that to dodge taxes

I would recommend moving your a*s from Rumania or try a US LLC
Click to expand...
currently my income is in Romania, and I want to move it to Cyprus and then to Marshalls...
What you recommend me to change/replace which country/company with llc
 
euroartdesign said:
So if I understood well:
When income comes to Romania 200k, then invoice from Cyprus for 195k and then invoice from USA LLS for 190k ?
Click to expand...

Better have something in US/CY with nominee or you are going to have problems in the long term

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Expat in Hong Kong - There are two ways to conquer and enslave a nation. One is by the sword. The other is by debt. - John Adams
 
GiGoGo said:
Better have something in US/CY with nominee or you are going to have problems in the long term
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The income comes to the Romanian companies, then the question is where to go, so there will be no problem? You mean Romania > then Cyprus or US, but if it stay in Cyprus I think there will be tax of 12%
 
Move to Cyprus, but staying in Ro and invoicing only Ro customers through a Cy company will get you in trouble

I suggest to find somebody that can help you in your specific case

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Expat in Hong Kong - There are two ways to conquer and enslave a nation. One is by the sword. The other is by debt. - John Adams
 
1. So you mean if CY invoices are only to Ro customers it is not good. So if the CY company sells and invoice our other clients in Europe (so the customers to the CY company wont be only Ro but from all over Europe) then there wont be problem.
2. What about the taxation (i think it is 12%) of the Cy company in Cyprus, how to optimise this ?
 
What kind of products you will sell ? Do you sell last user or companies ? Don't forget also there is VAT..

euroartdesign said:
1. So you mean if CY invoices are only to Ro customers it is not good. So if the CY company sells and invoice our other clients in Europe (so the customers to the CY company wont be only Ro but from all over Europe) then there wont be problem.
2. What about the taxation (i think it is 12%) of the Cy company in Cyprus, how to optimise this ?
Click to expand...
 
euroartdesign said:
2. What about the taxation (i think it is 12%) of the Cy company in Cyprus, how to optimise this ?
Click to expand...
You can setup another company in the Seychelles and transfer profits from the CY to the SC company just invoice the CY company and everything is fine. From my long years experience with CY & SC corps there is no one that ever check what the heck you are doing unless we speak millions.

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Admin said:
You can setup another company in the Seychelles and transfer profits from the CY to the SC company just invoice the CY company and everything is fine. From my long years experience with CY & SC corps there is no one that ever check what the heck you are doing unless we speak millions.
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Dear Adm, thank you. If Seychelles company is owner of my CY company and Seychelles company invoices the CY company - maybe this is not good, because they are connected. Is it Better CY company owner to be different from the Seychelles company?
 
You can move funds between these two tax entities tax free! Totally legal.

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euroartdesign said:
Ok, so you mean if the Seychelles company is owner of the Cy company there is no problem ?
Click to expand...
Usually not, I would consult a accounting firm or in Cyprus to get the latest details about it. Personally I know that this can be used and has been used this way for years with no one asking questions.

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