Where to incorporate for cheap banking?

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inector

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A friend of mine has a company in Marshall Islands, doing logistics (nothing shady).

He is considering incorporating somewhere else, because his current bank charges really high transfer fees and regularly asks him to come to the branch.

So he wants a business with low taxes (0-10%), low-cost EMIs, and a good remote physical bank later on (easy application).

BUT these banks should be okay to send money to Marshall Islands.

He lives in a territorial tax country.

Bulgaria?
Hong Kong?
Singapore?
 
I believe @Don or @CyprusLawyer101 @CyprusBusiness and @CyprusLaw can help you out with real solutions for your problem.

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inector said:
A friend of mine has a company in Marshall Islands, doing logistics (nothing shady).

He is considering incorporating somewhere else, because his current bank charges really high transfer fees and regularly asks him to come to the branch.

So he wants a business with low taxes (0-10%), low-cost EMIs, and a good remote physical bank later on (easy application).

BUT these banks should be okay to send money to Marshall Islands.

He lives in a territorial tax country.

Bulgaria?
Hong Kong?
Singapore?
Click to expand...
I see potential for some good structuring opportunity involving a CY co and his tax residency
 
CyprusLawyer101 said:
I see potential for some good structuring opportunity involving a CY co and his tax residency
Click to expand...
What would you suggest, some more information on what you see?

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inector said:
A friend of mine has a company in Marshall Islands, doing logistics (nothing shady).

He is considering incorporating somewhere else, because his current bank charges really high transfer fees and regularly asks him to come to the branch.

So he wants a business with low taxes (0-10%), low-cost EMIs, and a good remote physical bank later on (easy application).

BUT these banks should be okay to send money to Marshall Islands.

He lives in a territorial tax country.

Bulgaria?
Hong Kong?
Singapore?
Click to expand...
First, cheap EMI-s you mostly find in the EU or UK.
Marshall Islands could also get an EMI account, but it's not cheap.

Estonian residency + Estonian company with a branch office in Bulgaria can be a decent choice, and in some cases, even close to zero tax structure.
Especially if he qualifies for the CIT exemption.

1) on the Estonian level, there is no tax before profit distribution and no WHT, and combined with Estonian tax residency, the total tax is 0% if redistributing branch profits to yourself on Estonian level
2) Bulgarian branch - profit tax is by default 10%, but if you operate in an area with high unemployment, you get a 100% exemption from CIT. It applies to taxable persons that carry out production activities. If a municipality is no longer included in the list as a result of increased employment, the taxable person can retain the right to tax relief for a period of 5 years from the year in which the municipality was excluded from the list.
 
Don said:
Estonian residency + Estonian company with a branch office in Bulgaria
Click to expand...
Always a great choice
Don said:
if you operate in an area with high unemployment, you get a 100% exemption from CIT. It applies to taxable persons that carry out production activities
Click to expand...
Interesting, didn't know that
Don said:
Bulgarian branch
Click to expand...
Considering Bulgaria is part of FATF and he has a lot of transfers to offshore, like Marshall Islands and Belize, do banks run more checks at the moment?
 
12345 said:
usa llc
Click to expand...
Forgot to mention, his nationality is 3rd world and it's not welcome in USA (it's not Russia / Ukraine)

US has no non-resident physical banks and he can only apply for Mercury.
Don said:
Estonian residency + Estonian company
Click to expand...
No office to pick e-residency near him. He won't travel also.
CyprusLawyer101 said:
I see potential for some good structuring opportunity involving a CY co and his tax residency
Click to expand...
He tried Cyprus in the past, and he didn't like it (personal preference I guess)
-
P.S. Not trying to be mean about propositions, just that it's a complex use-case.
Bulgaria so far is a good choice, open for more.
 
inector said:
A friend of mine has a company in Marshall Islands, doing logistics (nothing shady).

He is considering incorporating somewhere else, because his current bank charges really high transfer fees and regularly asks him to come to the branch.

So he wants a business with low taxes (0-10%), low-cost EMIs, and a good remote physical bank later on (easy application).

BUT these banks should be okay to send money to Marshall Islands.

He lives in a territorial tax country.

Bulgaria?
Hong Kong?
Singapore?
Click to expand...
I wouldnt choose Bulgaria at the moment as its under EDD and many EMIs may decline the company only because of the jurisdiction.
HK ans Singapore are great, but considered to be offshore for EMIs, therefore the pricing may be high.
Cyprus can be a good choice like recommended below.

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Don said:
1) on the Estonian level, there is no tax before profit distribution and no WHT, and combined with Estonian tax residency, the total tax is 0% if redistributing branch profits to yourself on Estonian level
Click to expand...
So, you're telling me you can start a business in Estonia, make money, and not pay any taxes? That doesn't sound right. How much corporate tax does a regular business actually have to pay?
 
Propeller said:
So, you're telling me you can start a business in Estonia, make money, and not pay any taxes? That doesn't sound right. How much corporate tax does a regular business actually have to pay?
Click to expand...
All undistributed corporate profits are tax exempt.
Distributed profits are generally subject to the 20% CIT at 20/80 of the net amount of profit distribution.

However, dividends distributed by Estonian companies are exempt from CIT if the distributions are paid out of:
  • dividends received from Estonian, EU, European Economic Area (EEA), and Swiss tax resident companies (except tax haven companies) in which the Estonian company has at least a 10% shareholding profits attributable to a PE in the European Union, European Economic Area, or Switzerland
  • dividends received from all other foreign companies in which the Estonian company (except tax haven companies) has at least a 10% shareholding, provided that either the underlying profits have been subject to foreign tax or if foreign income tax was withheld from dividends received, or
  • profits attributable to a foreign PE in all other countries, provided that such profits have been subject to tax in the country of the PE.
 
Don said:
All undistributed corporate profits are tax exempt.
Distributed profits are generally subject to the 20% CIT at 20/80 of the net amount of profit distribution.

However, dividends distributed by Estonian companies are exempt from CIT if the distributions are paid out of:
  • dividends received from Estonian, EU, European Economic Area (EEA), and Swiss tax resident companies (except tax haven companies) in which the Estonian company has at least a 10% shareholding profits attributable to a PE in the European Union, European Economic Area, or Switzerland
  • dividends received from all other foreign companies in which the Estonian company (except tax haven companies) has at least a 10% shareholding, provided that either the underlying profits have been subject to foreign tax or if foreign income tax was withheld from dividends received, or
  • profits attributable to a foreign PE in all other countries, provided that such profits have been subject to tax in the country of the PE.
Click to expand...
Hi Don, I have been researching an Estonian Company and e-residency over the past few months and was intrigued about the 0% CT on undistributed profits. However as I am an unlucky UK resident and enjoying the pleasure of world-wide taxation does that bin the Estonia concept, as I will own / control the company? Would appreciate your insight thanks.
 
Maybe you guys should get back on topic and what OP is asking for? You may open a new thread with your questions.

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