Recent content by ElBotellon

Romania, afaik, has 10% flat tax on personal income and 8% on dividends. It seems you are already in a potentially good place to be.

With Ireland non-dom you cannot use the double tax treaty in place (often the treaty excludes the unremitted part). I believe in EU Cyprus (given also the amount of DTAs in place) for expats sounds the best place.

https://www.companies.gov.cy/en/bus...incidental-obligations/2-financial-statements "A company member-state of the European Community, which under the law of that state and European directives Directions is not obliged to submit the said financial statements, is exempted from the submission of...

an estonian company will always be resident in estonia due to incorporation (so eventually, it may become dual resident). wouldn't it be more clean a situation where you have an irish company non resident in ireland but tax resident in cyprus? so you skip totally the irish side (apart from...

I have read about MULLVAD but it has no external audit, while apparently both NordVPN and ExpressVPN (which are not free but cheaper than mullvad) had multiple audits. On top of this I believe all the vpns mentioned above should solve the issue related to DNS leaks. Please feel free to correct...

there is also a holding requirement of 1 year.

I believe here there is a misunderstanding because dividends of non-residents natural persons are subject to 8% WHT based on internal legislation. 10% on other kind of income (e.g. liquidation). Here a summary table from Minister of Finance RO: https://mfinante.gov.ro/apps/detali...ENITURILE...

the main topic is how to ensure that the tax resident certificate is issued under the specific DTA available and explicitly mention the DTA in the certificate. The point of Gediminas I believe is the possibility to have tax treaty protection (many countries have two versions of certificates...

Online I did not find any example of individual certificate. How a DTA-compliant certificate looks like? which wording they use? on the contrary, how a non-DTA compliant certificate would look like? i have found only examples of companies.

in your reference there is a table and a direct referral to art.5 of income tax. Interestingly capital gain (when not obtained in a self-employed/professional trading activity) seems excluded from GHS (cannot find it in the table and cannot find capital gain in art.5 definition). Does it mean...

this is not legal advice but as far as i remember for tax neutral result of reorganization you are obliged to keep nominal value also in the balancesheet of the holding, indeed if you revaluate the value this one is usually a taxable event. in practice the tax neutral reorganization is offering...

This is clear, what is not clear is if a EU citizen with MEU1 (so before 5 years are completed) satisfies the requirement of "permanent resident of the Republic" or not, which is a requirement often present in legislation.

It is a bit confusing for me because many laws recall the term "permanent resident" but the definition of permanent resident seems ambigous. According to your statement a person that has an MEU1 permanently resides in CY, but for the immigration law the MEU3 is considered a permanent resident...

I believe this topic belongs to the area of tax neutral reorganizations and rules are defined by each jurisdiction. If the reorganization is in EU then you can benefit from the implemented directives and tipically perform tax neutral reorganization. In your case you should google "exchange of...

first of all many thanks for your answer. Your answer assumes that liquidation proceedings are capital gain, while my doubt is exactly how liquidation proceedings qualify. Question 1 Are liquidation proceedings (income from liquidation of companies) treated as: a) dividends (subject to SDC) ...