MALTA/DUBAI/HUNGARY/CYPRUS - whats the best play in this scenario?
- Thread starter euzato
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Yes,
You can inject it as in kind contribution. Doing that the company will get exemption to withdraw same amount from the company tax free.
Or crypto could be lent to the company and paid back in cash.
In such case it has nothing to do with dividends.
This is an interesting take. I hope there will be more reactions to this post since every second thread is about cashing crypto and I've read them all and this is the first time I hear about this option. Can the capital be injected as crypto? Does this demand some special treatment at company's registration? Under what curcumstances can be capital taken out while not being a dividend? Convertion demands company to be registered at some cex, what are the conditions for this?
Yes
Articles of association must allow that
Reducing reserve capital, share capital or share premium
CEX are a great option. They do AML due diligence on onboarding.
This is not correct. Estonia requires only registering residence to qualify for tax residence, and you also qualify as a tax resident when you reside in Estonia for 183 days in one calendar year. If either of those two criteria is met, you are a tax resident according to the local law, which can be further overruled by double tax treaties - it sounds complex because it is.
E-residence is just a digital ID for non-tax residents. Estonia has effectively made some of its public services available to everyone in the world (who possess this digital ID).
Either a property in your own name or someone's consent is required to register your address with the property.
EU citizens have the right to a residence permit, while it's a bit more complicated for non-EU citizens since they need to apply for one, which has additional conditions.
If you invest 1M, you can get a residence permit without address registration, so it's possible to avoid tax residency.
In theory yes, but unless you lose your citizenship you are always tax resident at your home country.
Getting tax residency in another country only enables you to use double tax agreements, and with that you can tell them from now on you live in a different country so you will rather pay tax there instead of your passport country.
And yes most of the time it works, but your passport country can always say that oh you still talk with your family members there and visit them often, also get money to the banks there so you are still tax resident in your origin country.
Citizenship based tax residence only applies to USA and Eritrean citizens.
That doesn't sound correct. When you become tax resident in a new country, that becomes your basis for becoming tax non-resident in your passport (birth) country, assuming you meet the criteria, and it usually involves a slew of paperwork and process to get that status. Once it has happened, the original country would need evidence that you've triggered their residence tests since you became non-resident, otherwise it'd be pointless them pursuing you.
I didn't see this point being raised - what was your country of residence during the time you purchased and held the crypto?
No one seems to have pointed out the issue of exit taxes. If you want to be 100% legal, you should check if your country charges them. What's an exit tax? When you become tax non-resident from a country, that country may charge you capital gains tax on the value gain of your assets during your time of tax residency. You might get away with not declaring, but you're speaking about millions here. Read about Roger Ver's recent tax evasion conviction.
This sounds like a trade to me, a capital disposal and acquisition. You'd be trading a cryptocurrency for a valued share of a company, no?
Last edited: Jun 23, 2024
In-kind contributions to a company's share capital are considered equity investments, not trade. They involve transferring assets to the company in exchange for shares. These contributions are recorded as increases in capital and assets and create a long-term shareholder relationship. In contrast, trade transactions are one-time exchanges.
A contribution to an LLC taxed as a disregarded entity has no tax consequences because the entity is not considered an entity separate from its owner.
I'm not really qualified to answer US legal matters.
US LLC taxation is more complicated, and you need to consider your personal tax residence and how the US LLC is treated from a tax perspective both in the US and abroad.
Whether it's feasible to make an "in kind," contribution depends on tax implications but also matters such as bureaucratic hurdles such as whether you are required to obtain an opinion from a professional firm about the valuation of the contribution.
In conclusion - in kind contributions can be a great way to plan taxes.
Also if you can recommend which bank in BG ? i assume in HU it's OTP... So is it the subsidiary of OTP in BG (DSK) ? thanks
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