Recent content by totlori9

Jackfrost I mostly agree with your post, but slightly disagree in one question. The part I disagree with is: prcsc says he would like to set an llp up, no problem there. UK LLPs need at least two members, no fraud there. The LLP needs a managing member (not a director). So in order for him as...

Note that the 5K minimum tax is not applied on income that counts as capital gains. That stays tax free.

I meant exactly that. The OWNER of the car is the offshore company, the REGISTERED KEEPER of the car is what has to be a local entity in order to be able to get local license plates. The local entity can be either you as an individual or the locally registered 'commercial presence' of the same...

Hi, are you asking how the concept of the 'commercial presence' works?

If the work you carry out there is not complimentary on auxiliary on nature. The first link I have sent you discusses this. ...complementary OR auxiliary IN nature... Last edited by a moderator: Nov 13, 2018

It has nothing to do with your residence, see further: Permanent Establishment under the OECD Model Tax Convention

http://www.oecd.org/tax/transfer-pr...to-permanent-establishments-BEPS-action-7.pdf The words 'fixed base' and 'permanent establishment' are to be treated interchangeably in this context since from the early 2000s OECD treaties have morphed the articles discussing 'independent professional...

Thanks, you haven't said it, but I assume this is an EUR account you have, right?

CIM is a swiss bank. Switzerand agreed to CRS haven't they?

Thanks, That is in fact a subsidiary of OTP Bank. You said wire transfers from companies were ok. Would you be as kind and let us know if by transfers from companies you mean EUR transfer from an EU company, offshore company, or Montenegro company? And would you give a rough estimate on the...

I find accounting and business lawyer type services to be a lot cheaper in Hungary than in the UK where OP is currently, but I don't have experience in Bulgaria...

Do you mind sharing the bank name?

Since you are close to Serbia you can try opening an account for a Seychelles company there. The problem is even in the few banks where they say they are willing to open an account for a Seychelles company their system throws a red flag when they arrive at the name of the UBO of the company...

... a good enough reason on why you want to bank with them in the first place.

I honestly don't know the answer to that question. You are the only shareholder? Ask a local accountant how Bulgaria treats dividend income from a non treaty country, and don't forget if it is considered a CFC by your local laws chances are likely you'll have to pay more than 5%... I wouldn't...