10M.+ optimization tax residency when you have 3/4 bases.

[JohnnyDoe]

toums said:
you seem OVER Bear (pessimist),
Click to expand...

I'm just pragmatic and speaking from own experience

toums said:
and in that case France or another country can also challenge you if you live in any banana (caribbean) republic
Click to expand...

Thailand too is very banana

toums said:
for 6months more, just by argue 'you want to skip tax' and/or 'you are citizen of my country so i will tax you'. With these EXTREME examples, everything can happen to anyone.
Click to expand...

In the Caribbeans you can find the kind of protection that will save you and your money from such attacks, provided you have a good setup and a real base. It might also be true in Thailand, I don't know.

toums said:
Not agree again with that. What the point with rent or buy? I can rent a 300 sqm penthouse at 5K$+ a month in BKK or buy a T1 40sqm for 150K$.. What is the more relevant for tax residency?
Click to expand...

None, because they expect a guy with your profile to own more than a T1 or a rented apartment. I remember Pavarotti claiming to live in a flat in Monaco where he probably couldn't even physically fit”¦ and that was maaany years ago, in a veeery different world. He spent much less than 6 months in Italy, nevertheless he was forced to pay big money to settle with the tax authorities.


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@JohnnyDoe ”“ Your #1 Source for Guidance in Different Offshore Fields​

 

[Mercury]

JohnnyDoe said:
That's the point. It has to be a real residence, they makes sense in the eyes of a prosecutor and a judge. Try to convince them that a $10m+ worth guy really lives in a rented condo and that's all the ties he has with that country.
Click to expand...

OP has left France more than 10 years ago. Supposing he cashed out offshore after his move, there is/was no exit tax related to crypto assets. France does not have a clue of his net worth and could not care less as long as he's declared residing abroad providing a real address (continuing lease or title deed) and he meets the 3 criteria (all) not to be considered resident in France for tax purposes.

The fact that the residence address you provide does not match your net worth does not matter either, as long as you don't effectively live in France.

The slight difference maybe with some other tax-aggressive countries is that, until now, France does not require by law a tax residence elsewhere to be considered non-resident for tax purposes. Just not meeting the FR tax residence criteria is enough.

 

[nasdaqtradfiguy]

Any comments regarding keeping the assets at personal level Vs incorporating?

Eg Belize company

Or X holding company owning a Wyoming LLC?

 

[JackAlabama]

Mercury said:
OP has left France more than 10 years ago. Supposing he cashed out offshore after his move, there is/was no exit tax related to crypto assets. France does not have a clue of his net worth and could not care less as long as he's declared residing abroad providing a real address (continuing lease or title deed) and he meets the 3 criteria (all) not to be considered resident in France for tax purposes.

The fact that the residence address you provide does not match your net worth does not matter either, as long as you don't effectively live in France.

The slight difference maybe with some other tax-aggressive countries is that, until now, France does not require by law a tax residence elsewhere to be considered non-resident for tax purposes. Just not meeting the FR tax residence criteria is enough.
Click to expand...

another angle to think about it. Hows op social media profile looking like?
Is it more similar to a) hushpuppy or is it b) ghost like ie non existing?

If a) id opt for @JohnnyDoe s advice.

 

[Mercury]

JackAlabama said:
another angle to think about it. Hows op social media profile looking like?
Is it more similar to a) hushpuppy or is it b) ghost like ie non existing?

If a) id opt for @JohnnyDoe s advice.
Click to expand...

Sure. If you favour your freedom and privacy in an increasingly connected world, the best attitude is "Pour vivre heureux, vivons cachés" as French say.

 

[toums]

JohnnyDoe said:
In the Caribbeans you can find the kind of protection that will save you and your money from such attacks, provided you have a good setup and a real base. It might also be true in Thailand, I don't know.
Click to expand...

Can you give me a quick 'résumé' of how you can 100% be safe with all 'attacks' in caribbeans (I assume you are in the Bahamas?)

JohnnyDoe said:
None, because they expect a guy with your profile to own more than a T1 or a rented apartment. I remember Pavarotti claiming to live in a flat in Monaco where he probably couldn't even physically fit”¦ and that was maaany years ago, in a veeery different world. He spent much less than 6 months in Italy, nevertheless he was forced to pay big money to settle with the tax authorities.
Click to expand...

I read the story. Well I don't know the sqm price in Monaco in middle 90s (in Francs, not euros), maybe around 10K€/sqm ? we were at 25K per sqm (average) late 2000s, and 50K now.. He paid 200K, so it look like he tooks a Studio, but his net worth was 300M. at this time so ratio 1/1000. In my "small" level, and based lets say on 10M. it's mean i live in a 10K flat... (even not a garage then...). Also Monaco is only few km from italian borders.. and maybe we dont know also all his other stories..

So, from YOUR opinion, in the situation I explained, you would say it's much more 'safe' to be at least 90days in UAE (to get the certificate) and let's say 4months in Thailand OR staying at least 180 days in thailand (and not at all UAE) OR still keeping NHR for now as 6months not required but tax certificate + DTAs (but not optimized for traditionnal market capital gains AND still EU country..)

Mercury said:
OP has left France more than 10 years ago. Supposing he cashed out offshore after his move, there is/was no exit tax related to crypto assets. France does not have a clue of his net worth and could not care less as long as he's declared residing abroad providing a real address (continuing lease or title deed) and he meets the 3 criteria (all) not to be considered resident in France for tax purposes.

The fact that the residence address you provide does not match your net worth does not matter either, as long as you don't effectively live in France.

The slight difference maybe with some other tax-aggressive countries is that, until now, France does not require by law a tax residence elsewhere to be considered non-resident for tax purposes. Just not meeting the FR tax residence criteria is enough.
Click to expand...

Yes, I started to made my money AFTER i leave France, I had even not 6 digits when I left so.. the 3 criterias are met since I left, French Tax office was warned in 2013 I moved abroad and I am registered at the 'french people living abroad' consulate, according to the different countries i leave since I left France.

@wellington If you want to send me a PM feel free, I am also currently in Thailand.

 

[JohnnyDoe]

toums said:
Can you give me a quick 'résumé' of how you can 100% be safe with all 'attacks' in caribbeans (I assume you are in the Bahamas?)
Click to expand...

You should explore the Mentor Gold Group, better not to talk of certain details in public.

toums said:
So, from YOUR opinion, in the situation I explained, you would say it's much more 'safe' to be at least 90days in UAE (to get the certificate) and let's say 4months in Thailand OR staying at least 180 days in thailand (and not at all UAE) OR still keeping NHR for now as 6months not required but tax certificate + DTAs (but not optimized for traditionnal market capital gains AND still EU country..)
Click to expand...

I would say that the safest option is to stay 183 days min in Thailand, with a real presence on the ground. And with a proper setup to protect your assets.

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@JohnnyDoe ”“ Your #1 Source for Guidance in Different Offshore Fields​

 

[wellington]

toums said:
I moved abroad and I am registered at the 'french people living abroad' consulate, according to the different countries i leave since I left France.
Click to expand...

My neighbour (Belgium) mentioned the need to do this, and Swiss neighbours confirmed.

Can assure you, if as a Brit i had to do it, i'd renounce.

The Belgium also has to file taxes annually.

toums said:
@wellington If you want to send me a PM feel free, I am also currently in Thailand.
Click to expand...

I'm down south (Phuket).

JohnnyDoe said:
I would say that the safest option is to stay 183 days min in Thailand, with a real presence on the ground. And with a proper setup to protect your assets.
Click to expand...

Thailand is ok, both holding a overseas holding company and or holding Director position in a operational overseas company.

They do charge tax on remittances mind, but as for all else they have confirmed they have no interest at this time.

Though with the socialists now in charge - who knows.

Mercury said:
Sure. If you favour your freedom and privacy in an increasingly connected world, the best attitude is "Pour vivre heureux, vivons cachés" as French say.
Click to expand...

Use Twitter (s**t post under alias).
Don't use FB/Others.

nasdaqtradfiguy said:
Any comments regarding keeping the assets at personal level Vs incorporating?
Click to expand...

Just don't do a BVI, have to do full-accounting and reporting now, and also KYC/EDD just to on-board an accountant lol.

 

[toums]

wellington said:
My neighbour (Belgium) mentioned the need to do this, and Swiss neighbours confirmed.

Can assure you, if as a Brit i had to do it, i'd renounce.

The Belgium also has to file taxes annually.
Click to expand...

It's not mandatory as a French to do that, but it's one more element to prove you REALLY live abroad. As a french citizen, expatriate, no need to fill anything annually. Except if you have income derived from France or Real estate there.

wellington said:
I'm down south (Phuket).

Thailand is ok, both holding a overseas holding company and or holding Director position in a operational overseas company.

They do charge tax on remittances mind, but as for all else they have confirmed they have no interest at this time.
Click to expand...

Ok I am in BKK actually.

Good to know for the possibility to hold /manage any oversea company (as director ot not) from the Kingdom without trouble.

Do you have information or not of the necessity to stay MINIMUM 6 months there for the tax residency? I read somewhere you can ask for your tax number there, even without staying 6months if you said to them you want this tax number to pay some tax there..

 

[Mercury]

toums said:
Do you have information or not of the necessity to stay MINIMUM 6 months there for the tax residency? I read somewhere you can ask for your tax number there, even without staying 6months if you said to them you want this tax number to pay some tax there..
Click to expand...

You can get a Thai TIN if you have local income such as salary or bank account interest, however that does not mean you are de facto TH tax resident. The only condition to be considered Tax resident in Thailand is to stay in-country at least 180 days during a calendar year.

 

[JackAlabama]

toums said:
It's not mandatory as a French to do that, but it's one more element to prove you REALLY live abroad. As a french citizen, expatriate, no need to fill anything annually. Except if you have income derived from France or Real estate there.



Ok I am in BKK actually.

Good to know for the possibility to hold /manage any oversea company (as director ot not) from the Kingdom without trouble.

Do you have information or not of the necessity to stay MINIMUM 6 months there for the tax residency? I read somewhere you can ask for your tax number there, even without staying 6months if you said to them you want this tax number to pay some tax there..
Click to expand...

Thailand - Overview PWC
best resource ever invented by pwc to answer this question.

a tin does not mean anything nor does it mean youre tax resident.
I have about 7 personal tins or so and pay tax to none of them bc ive left these territories or did not move there in the end 😉

 

[toums]

JackAlabama said:
Thailand - Overview PWC
best resource ever invented by pwc to answer this question.

a tin does not mean anything nor does it mean youre tax resident.
I have about 7 personal tins or so and pay tax to none of them bc ive left these territories or did not move there in the end 😉
Click to expand...

Thanks for the link.

Ofc a TIN doesn't mean you are tax resident. But without TIN, seem also obvious you are not tax resident too (or more difficult to prove it to another country).

My point was more about to have the TIN + declare some income in Thailand, without necessarily be there more than 180days.

wellington said:
Thailand is ok, both holding a overseas holding company and or holding Director position in a operational overseas company.

They do charge tax on remittances mind, but as for all else they have confirmed they have no interest at this time.
Click to expand...

I don't know if you are into crypto, but I cannot find what is currently applicated in Thailand regarding the WHT.

I read in some place that thailand tax 15% (WHT) for any capital gain in crypto. I suppose CEX in Thailand charge / take directly maybe 15% of your selling? But I never saw any WHT applied on Kraken or Binance for example.

As these exchanges are also located outside Thailand, is there any loophole / specifity to be tax free (like the same for the traditionnal financial market capital gains) ?

Don't know the reliability of this website : Thailand Cryptocurrency Income Personal Tax
If I understand well, the tax should only apply if you cash out from a CEX located in Thailand. If abroad, and not remitted in Thailand, the 15% WHT not apply. Someone can confirm?

Last edited: Mar 20, 2024

 

[PinkCat]

You must be my forum doppelgänger since we are in very similar situations!

The thing is that I like Dubai and that pretty much solves it for me. Big, safe city, that has everything you need and relatively central location for flying. Anyway, let me add couple of things.

- As someone influenced by BBB (bye bye big brother book) there was a term PT (perpetual traveller) and the idea was that if you don't spend in any country more than 6 months, none of them can have claim on your taxes. Reading through ALL of this thread I get the impression that is no longer the case, hence your pursuit for tax residence. Would love confirmation on this or some legal precedents where a PT was sued for taxes?

- To me it seems you are pretty safe regarding France since you have more than closed any ties with it but if that helps here is an idea. If you believe in crypto long term (like I do) and don't plan to sell it all at some point you can use few DeFi protocols to borrow against it, hence not generating taxable event since you will be spending DEBT and be in PD (perpetual debt) thus solving the issue at its core. Of course there are no legal precedents yet at how a judge will interpret loan from a protocol and not a bank, so just something fun to think about.


Will try to read the thread again and provide more input as soon as i'm feeling better, not feeling well today and might have missed something.

 

[Meta]

toums said:
Thanks for the link.

Ofc a TIN doesn't mean you are tax resident. But without TIN, seem also obvious you are not tax resident too (or more difficult to prove it to another country).

My point was more about to have the TIN + declare some income in Thailand, without necessarily be there more than 180days.



I don't know if you are into crypto, but I cannot find what is currently applicated in Thailand regarding the WHT.

I read in some place that thailand tax 15% (WHT) for any capital gain in crypto. I suppose CEX in Thailand charge / take directly maybe 15% of your selling? But I never saw any WHT applied on Kraken or Binance for example.

As these exchanges are also located outside Thailand, is there any loophole / specifity to be tax free (like the same for the traditionnal financial market capital gains) ?

Don't know the reliability of this website : Thailand Cryptocurrency Income Personal Tax
If I understand well, the tax should only apply if you cash out from a CEX located in Thailand. If abroad, and not remitted in Thailand, the 15% WHT not apply. Someone can confirm?
Click to expand...

Regarding crypto I'm not sure what are the laws but I can tell you what's happening now.

A few years ago there were no withholding taxes for crypto and it was easy to register at local crypto exchanges without any formal ties to country (except a local bank account which would be used for deposit / withdraw).
In 2023 some foreigners got their crypto exchange accounts closed / frozen / reKYC requested / reKYC requested but no options for foreign docs. There were some regulatory changes and apparently many exchanges were not sure what are the requirements for foreigners. It was confusing.
I got a scary-looking message popping up all the time "All deposits stopped, resend your docs" with a link to a crypto exchange page saying that I'm fully verified.
Just a couple months ago verification became available again. bitkub.com which I use asks for more docs than before, but it's mostly to effect of "more ties to Thailand than a tourist". A letter from university would suffice for a student, or a driving license which is easy to get. No formal requirement to have a work permit / be a tax resident / provide Thai TIN.
Still no withholding from crypto exchanges. Work fine. Not exactly sure if they are going to slap me with a 15% bill on turnover by the end of year. Well, things are mostly not crispy clear here but tend to work out well, one just needs to get used to that...

 

[toums]

Meta said:
Regarding crypto I'm not sure what are the laws but I can tell you what's happening now.

A few years ago there were no withholding taxes for crypto and it was easy to register at local crypto exchanges without any formal ties to country (except a local bank account which would be used for deposit / withdraw).
In 2023 some foreigners got their crypto exchange accounts closed / frozen / reKYC requested / reKYC requested but no options for foreign docs. There were some regulatory changes and apparently many exchanges were not sure what are the requirements for foreigners. It was confusing.
I got a scary-looking message popping up all the time "All deposits stopped, resend your docs" with a link to a crypto exchange page saying that I'm fully verified.
Just a couple months ago verification became available again. bitkub.com which I use asks for more docs than before, but it's mostly to effect of "more ties to Thailand than a tourist". A letter from university would suffice for a student, or a driving license which is easy to get. No formal requirement to have a work permit / be a tax resident / provide Thai TIN.
Still no withholding from crypto exchanges. Work fine. Not exactly sure if they are going to slap me with a 15% bill on turnover by the end of year. Well, things are mostly not crispy clear here but tend to work out well, one just needs to get used to that...
Click to expand...

Thanks for sharing your experience. TBH I have no advantage to open a new account on bitkub.com (local exchange) IF i move to thailand as tax residency. I have my 'offshore' CEX Binance and Kraken, and I am fully verified with really HIGH limit for daily cashout in fiat with kraken (more than 10M.$ / daily) and registered for dealing with OTC. And it's working perfectly.

My question was mostly if it's affect the taxation or not (15% WHT or any income tax) in Thailand, if you cash out with offshore CEX (cf : kraken / binance) AND you don't remit anything in Thailand.

 

[Mercury]

toums said:
My question was mostly if it's affect the taxation or not (15% WHT or any income tax) in Thailand, if you cash out with offshore CEX (cf : kraken / binance) AND you don't remit anything in Thailand.
Click to expand...

Thailand does not tax not remitted foreign-sourced income, only remittance (exemptions may apply) into Thailand.

 

[toums]

Mercury said:
Thailand does not tax not remitted foreign-sourced income, only remittance (exemptions may apply) into Thailand.
Click to expand...

I understood / know that point, but I had a doubt regarding the crypto taxation (capital gain) in Thailand.

So for you, if you cash-out without using a Thai crypto exchange AND not remit the money into Thailand it's totally tax free?

Same as for dividends/interets/capital gain with brokers like IB, till you don't remit the money in Thailand. Correct?

 

[Mercury]

toums said:
I understood / know that point, but I had a doubt regarding the crypto taxation (capital gain) in Thailand.

So for you, if you cash-out without using a Thai crypto exchange AND not remit the money into Thailand it's totally tax free?

Same as for dividends/interets/capital gain with brokers like IB, till you don't remit the money in Thailand. Correct?
Click to expand...

Correct.

 

[JackAlabama]

territorial / non dom systems are a pretty good starting point to look at.
Depending on how they work in practice they can be a serious alternative to nomading or 0 tax places.

 

[TRGali]

Intersting thread. Toums, one addition about Dubai, as you mentioned it a few times, spending 90 days there only give you a local (not internationally recognized) tax residency certificate. If you want to get the international one, it's 6 month minimum. Dear OECD...

Don, you mentioned Qatar residency with owning a flat there. Do you know if they give the tax residency certificate with such that setup ?