Recent content by 2fire

  1. 2fire

    European Company SE (Societas Europaea)

    Does it hold other EU companies or works internationally? I am trying to understand how does SE establish works in other member states.
  2. 2fire

    European Company SE (Societas Europaea)

    If I am correctly understanding the actual benefit that you don't need to setup subsidiaries or branches and you can operate locally in each EEA member. Another benefit which seems to me interesting is that you will have nice solid financial statements and you can benefit with easier financing...
  3. 2fire

    European Company SE (Societas Europaea)

    Dear JohnLocke, By SE I didn't mean Sweden, I mean novel legal form in Europe: https://europa.eu/youreurope/busine...s/setting-up-european-company/indexamp_en.htm
  4. 2fire

    European Company SE (Societas Europaea)

    Dear OCT members, Has anyone had experience with a European Company (SE)? How does it work? For example, if I have a factory in EU Country A, sales offices in EU Countries B and C, and I decide to merge them into a European Company (SE) based in Country D, what will happen to the merged...
  5. 2fire

    Best setup to avoid European withholding tax? Anything better than Malta?

    Luxembourg seems offers a generous participation exemption regime for holding companies, which can result in significant tax savings. Dividend Income: Dividends received from qualifying subsidiaries are exempt from corporate income tax (CIT), municipal business tax (MBT), and net wealth tax...
  6. 2fire

    Non-domiciled tax resident individual in Ireland

    Thank you for sharing
  7. 2fire

    Non-domiciled tax resident individual in Ireland

    No worry. I have a great plan. I will spend winter time in Ireland and summer time in UAE Will enjoy my life fully!
  8. 2fire

    Non-domiciled tax resident individual in Ireland

    In Ireland, the concept of domicile is important for tax purposes. It refers to the country that a person considers their permanent home and is distinct from nationality and residency. An individual can only have one domicile at any given time, and it is usually inherited from the father at...
  9. 2fire

    Best banks for the usd 100,000 trust or foundation

    Appreciate your answers on this matter. As usual very interesting to hear your opinion.
  10. 2fire

    Cyprus R&D center

    Am I correctly understanding that CY company doesn't have a WHT paid to foreign companies which are not EU blacklisted. In such way CY company pays 2.5% CIT and could pay dividends to UAE foundation with 0% WHT.
  11. 2fire

    Cyprus R&D center

    Thank you for your reply. Would it be possible to hold this CY R&D by foundation registered in UAE and find CY banking for that?
  12. 2fire

    Cyprus R&D center

    Dear OCT members, I am genuinely performing R&D in one of my factory in EU. Occasionally we event making projects which are co funded by EU. I wonder if I can setup a foundation in UAE, which would setup a R&D center in Cyprus. I would hire locally engineers to perform R&D functions. Then I...
  13. 2fire

    List of Territorial Tax Countries with formal and de-facto treatment of foreign income

    Dear Marzio, Thank you for creating spreadsheets about territorial tax. Does it also works for collecting royalties, licenses fees or there is also some other countries which has special zero tax policy for collecting royalties?
  14. 2fire

    Best banks for the usd 100,000 trust or foundation

    Thank you very much for your answer As I can understand main goal of foundation is protection of assets from potential attack on UBO. Would you use foundation in your structure if there is would be no issues with banking for subsidiaries?
  15. 2fire

    Best banks for the usd 100,000 trust or foundation

    Dear Sols, It is seems that you had some experience with foundations, would you mind to share your experience about banking experience. How banks would look to operating company, which is owned by holding company, which is owned by foundation? Technically foundation has no shareholders, what...
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