CRS questions

[yngmind]

Hey guys, I wanna corporate in Estonia or Hong Kong or Singapore, the thing is all countries automatically will report it to my home country via CRS.

The questions is what ways to bypass it?

That's what I think will work:
- nominee services
- make a partnership with companies so I won't be in the documents as individual

is there is other ways and comment please about the partnership, will it work? I think better to choose some countries with no public companies record for partnership like Delaware LLC in us,


thanks.

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[Gediminas]

Hi,

Nominees won't help. You will still have to disclose the UBO information.

What is your citizenship and tax residency?

You can check this link - Exchange relationships - Organisation for Economic Co-operation and Development

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[yngmind]

Gediminas said:
Hi,

Nominees won't help. You will still have to disclose the UBO information.

What is your citizenship and tax residency?

You can check this link - Exchange relationships - Organisation for Economic Co-operation and Development
Click to expand...

Russian and Russia is my tax residency

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[yngmind]

Gediminas said:
Hi,

Nominees won't help. You will still have to disclose the UBO information.

What is your citizenship and tax residency?

You can check this link - Exchange relationships - Organisation for Economic Co-operation and Development
Click to expand...

thanks for the link, been looking for it since some forum members asking about CRS, I know all the CRS relationships with Russia and any country in the world, that's why I'm asking, is there is any way to incorporate in CRS countries which exchanges info with my home country and still don't be reported.


what about partnership scheme?

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[onemansomewhere]

There is a way, how to obtain Ukrainian citizenship, if you are russian. It can be done in as short as 3-5 months. It is not cheap, but it is possible. Ukraine is not part of OECD CRS. And it will not become in next 5-10 years. And you can incorporate a structure with ukrainian documents. In that situation, nothing will be reported.

 

[yngmind]

onemansomewhere said:
There is a way, how to obtain Ukrainian citizenship, if you are russian. It can be done in as short as 3-5 months. It is not cheap, but it is possible. Ukraine is not part of OECD CRS. And it will not become in next 5-10 years. And you can incorporate a structure with ukrainian documents. In that situation, nothing will be reported.
Click to expand...

Thank you for advice broski, will consult with my lawyer


interesting info

just googled it, I will have to lose my citizenship to get Ukrainian one, I wont do that.


I wanna get St Kitts and Nevis for 150k$

Last edited: Apr 28, 2020
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[onemansomewhere]

There is a way how to obtain ukrainian without loosing a russia.

 

[Btraveler]

yngmind said:
Hey guys, I wanna corporate in Estonia or Hong Kong or Singapore, the thing is all countries automatically will report it to my home country via CRS.

The questions is what ways to bypass it?

That's what I think will work:
- nominee services
- make a partnership with companies so I won't be in the documents as individual

is there is other ways and comment please about the partnership, will it work? I think better to choose some countries with no public companies record for partnership like Delaware LLC in us,


thanks.
Click to expand...

Hello @yngmind The most legal and transparent could be in Estonia. You don't have to pay any tax as you mantain the money in the company. Then, you can bill from other companies to your estonian company whatever you want, but always documented...

 

[Limelight]

Btraveler said:
The most legal and transparent could be in Estonia. You don't have to pay any tax as you mantain the money in the company. Then, you can bill from other companies to your estonian company whatever you want, but always documented...
Click to expand...

Is this actually legal?

Wouldn't it be seen as tax evasion if I e.g. billed my Estonian company from under my Romanian microcompany, being the sole owner of both of them?

 

[anotherone]

I think there is a wrong asumption here.
CRS =>
If you have a personal bank account in another country, the tax atuhority of this country reports you to your fiscal residency authority
If you have a corporate bank account in another country, the tax authority of this country does not report you.

Example:
I live somewhere in Europe, my Irish company have a corporate bank account but I don't live in Ireland. No one reported this bank account to the tax authority where I live. I never used a nominee in ireland. I think nominees can be useful for American citizens not for european citizens.

 

[Btraveler]

anotherone said:
I think there is a wrong asumption here.
CRS =>
If you have a personal bank account in another country, the tax atuhority of this country reports you to your fiscal residency authority
If you have a corporate bank account in another country, the tax authority of this country does not report you.

Example:
I live somewhere in Europe, my Irish company have a corporate bank account but I don't live in Ireland. No one reported this bank account to the tax authority where I live. I never used a nominee in ireland. I think nominees can be useful for American citizens not for european citizens.
Click to expand...

About that, yes and no. Your corporate company bank account has an UBO, which is you. So this will be reported under CRS to your home country

 

[anotherone]

Btraveler said:
About that, yes and no. Your corporate company bank account has an UBO, which is you. So this will be reported under CRS to your home country
Click to expand...

Where did you find this information. here is what I have from the CRS handbook

A passive Non financial entity (passive NFE is a company that is not a trading company and gets more than 50% of its income as dividends, interests, royalties (passive income).

An Active NFE The term Active NFE means any of the following: ”¢ Active NFEs by reason of income and assets: º For the preceding calendar year or other appropriate reporting period, less than 50% of its gross income is passive income (including dividends, interest, annuities and rent) AND less than 50% of its assets are held for the production of passive income. It is expected that the majority of organisations will fall into the Active NFE

https://www.oecd.org/tax/exchange-o...e-of-financial-information-in-tax-matters.pdf
https://business.aib.ie/content/dam...uidance/FATCA-Entity-Classification-Guide.pdf
In other words, the account holder is reported only in case of a company that earns its money from dividends, interests, royalties.

 

[Btraveler]

In that case, yes, seems to be ok. However, your (for example) European high tax country will consider that your activity is directed from your home own country where you reside and tax your company as local. That is information from my tax advisor

 

[anotherone]

Btraveler said:
In that case, yes, seems to be ok. However, your (for example) European high tax country will consider that your activity is directed from your home own country where you reside and tax your company as local. That is information from my tax advisor
Click to expand...

I know what you mean. but i don't live in a european country where it is the case. So, I had an Irish company and once I went to dublin and I visited my virtual office. The manager told me they used to receive letters from the tax authority of Germany and Italy to tell them if the management of those companies took place in Ireland.
People of the virtual office were used to this type of mail.
I don't remember how they handled it but they handled it well. I was not in this situation because I was in france and the law is different in France. In France, a company is located where it has her main assets.
All the virtual offices are used to tax authorities trying to check it.