He can't move
He uses an Italian LLC
I thought about Malta too and even if on the surface CIT is 35% you'll end up paying 5% and that would fall into Italian CFC rules.
IT LLC to offshore
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He can't move
He uses an Italian LLC
I thought about Malta too and even if on the surface CIT is 35% you'll end up paying 5% and that would fall into Italian CFC rules.
Some unconventional setups, like using a non-profit abroad, could potentially run under the radar from CFC and CRS.
With an NGO, there are no shares, and members are not disclosed publicly. UBO is potentially not reported anywhere or is someone else who is not real beneficiary.
I can agree that in general, such endeavours can be risky, as was commented before.
i thank you simply use it as your personal bank account then haha
jokes aside, that would be interesting. a lot of big players do so.
so is there a scheme you think about and how many layers are needed, estimated cost etc for it?
You can take money out as a salary, loan or liquidate it, and liquidation can be structured tax-free as well.
In certain cases, you can even structure it as a charitable entity so even donations to a certain extent are deductible as per EU law.
The arrangement should have some economical substance, and people's refined tastes often differ in this matter.
Last edited: Nov 16, 2023
The harder you try, the harder they will hit you. Unless you are talking of €10k per year, they can and will go as far as sending a GdF marshal abroad to check your setup, offices and background of the business. They will write a long (hundreds of pages) report with a fancy title and even an illustrated front cover, that will end on the table of the Procuratore della Repubblica. At that point, a 5-6 years long and expensive nightmare will start.
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Concerning GdF marshals, I've even heard of some regular guys paid by the tax authorities to snitch after such service providers who they believe help to facilitate so-called schemes. So, in that regard, having sufficient economic substance is highly advised.
sounds like expirienced and well known expiriences... better not to have the same!
yes they exist, but i think everywhere in the world....
but what you mean with "sufficient economic substance" ?
and talking in numbers... if we say lower 6 numbers is it worth then?
It means people working for your holding, a director that you pay 50K a year, office space that you rent, salaried employee.
And even in this case your structure could fall into GAAR meaning that if there are no other reasons beside tax reduction that justify your holding it will be disregarded and you'll end up like @JohnnyDoe said.
That's reality. It is better to face the truth than to receive a letter from tax office.
In any case why don't you consider moving to Switzerland or San Marino?
Both are pretty compelling options for those who want to stay as close as possible to Italy.
i already have a setup that needs the italian LLC. I just wanted to "upgrade" it for better taxation.
thank you all for advises, i will considering them.
but what i do not understand after all, for what reasons are then the anonymous LLCs and all the other stuff offered here? because in my opinion they could be used in my case. i just have to say "i got frauded" and the money is somewhere on an anonymous LLC... just for example.
Because there will always be the white side and the black side of doing things.
You decide, based on your risk appetite, where you want to be.
Then you'll have to pay Italian taxes and look for a tax accountant that will help you reduce those taxes.
Curious...Why does your setup NEED a LLC? Why are you unable to move if you desire to reduce your taxes?
In most jurisdictions, you have UBO registers and have to report the UBOs (beneficiaries).
Using such entities without reporting yourself as UBO is often considered illegal money laundering. Achieving anonymity legally is more complicated.
It sounds like this is something you have experienced and would like to avoid, while also warning others against making the same mistake.
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Disclaimer: Nothing I say should be taken as tax, legal or financial advice. Anything I say is for general informational purposes only. Always seek independent professional advice.
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Yes, and I'm not the only one who had the privilege to receive this treatment. My case didn't reach court, but doing everything by the rules is not sufficient to guarantee the same result.
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