Foreign company - taxes and residency problem

[Delta]

Hi,

I ve problem to find clear answer on my questions.
Lets say I ve company registed in other country B, which has csr and double tax threaty with a country A, where I am resident and has also csr. Company is used for withdrawing money from short term trading of financial derivatives.
Do I need to in this case pay any taxes to a country A, where I am resident or just to a country B, wheres company registered, when I ll withdraw money in cash via ATM or transfer to bank acc out of company? Which countries provide the lowest taxes from capital gains without having residency, if not necessary.
Will country A of residency get via csr automatic reports from a corporate company registered in different country B, while owner is resident of that so called country A?

Regards,
Delta.

Seems like without residency including company in other country its useless unless its on some nominee, who has residency there.

Another case, if I ve two residencies. Do I pay taxes in residency wheres company or both?

Last edited: Jan 6, 2024

 

[Sols]

Delta said:
I ve problem to find clear answer on my questions.
Lets say I ve company registed in other country B, which has csr and double tax threaty with a country A, where I am resident and has also csr. Company is used for withdrawing money from short term trading of financial derivatives.
Do I need to in this case pay any taxes to a country A, where I am resident or just to a country B, wheres company registered, when I ll withdraw money in cash via ATM or transfer to bank acc out of company?
Click to expand...

Yes, you ned to pay taxes in Country A, unless Country A is a tax haven or unless there is a tax treaty between A and B whereby your company pays tax in B and only B.

So it depends on the relevant laws in A and B.

Most likely, under the laws of Country A, your company in Country B is treated practically the same as a company incorporated in Country A. Your company is tax resident and/or has a permanent establishment in Country A, which means it pays tax just like a company incorporated in Country A.

Delta said:
Which countries provide the lowest taxes from capital gains without having residency, if not necessary.
Click to expand...

I'm not sure what you're asking here exactly. You're taxed based on residence (and in some rare cases citizenship), and where income is earner. If you don't live in X and don't work/do business in X, you don't pay tax in X.

Delta said:
Will country A of residency get via csr automatic reports from a corporate company registered in different country B, while owner is resident of that so called country A?
Click to expand...

CRS is still young and mistakes are made but in principle, yes.

Delta said:
Seems like without residency including company in other country its useless unless its on some nominee, who has residency there.
Click to expand...

Correct.

Delta said:
Another case, if I ve two residencies. Do I pay taxes in residency wheres company or both?
Click to expand...

Depends on the relevant laws. It could be both or it could be one. Varies a lot.

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This is the probably the answer to your question.

 

[Don]

Delta said:
Will country A of residency get via csr automatic reports from a corporate company registered in different country B, while owner is resident of that so called country A?
Click to expand...

Yes, in principle, but there are also exceptions to the rules.
Reporting happens for reportable persons/accounts.