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Hi all, I am getting a bit confused and I would like to get more clarity. CASE 1 If company X is a Romanian tax resident company (micro-enterprise taxed at 1% or 3%), the distribution of dividends to a non resident individual is subject to which taxes? (Witholding tax? Dividend tax?) I...

if she is joining you as non-EU spouse I believe she has the right to stay without registration 90 days per country. I am saying this because she does not have a schengen visa but a european residence permit issued as family member of eu citizen which - by definition - is entitled to travel...

the D&G judgement (but also Cadbury Schweeps) was based on freedom of establishment, so I see a risk of challenge for UK since the EU freedom of establishment are not anymore applicable (under EU freedoms only "Wholly artificial arrangements" can be prosecuted by a country legislation).

I have read that is possible for people being employed and working abroad (but within EU) be exempted from GHS presenting S1 (social security benefits) of the other EU country. Is this doable? I am asking this because even on dividends from CY company there could be GESY contribution (which...

yes thanks, please feel free to PM. In terms of compliance for small holdings there is an interesting news regarding absence of audit, with a "review" . For definition of review I found this but no idea about cost impact. To provide external parties with a basic level of assurance on the...

guys, I don't know how you manage to use non-resident companies for B2B transactions. Tipically when there are services, consultancy etc to avoid witholding taxes countries ask tax residence and beneficial ownership of the payee (to avoid conduit companies). So in general i would not feel...

romanian girls are way better looking than portuguese . should you move for girls pls consider Bosnia (republic of Srpska), Serbia, Croatia, Estonia, Latvia,Lithuania, Belarus,Russia (I know not the safest place nowadays) and even Moldova which is very close to you. In portugal the average...

I don't want to "ruin the party" or be the pain in the bottom in this discussion, but I would be VERY SCARED to receive 100K cash by unknown people with unknown source of funds. If by chance such money is connected to any sort of crime you could be involved in a money laundering scheme. Even...

Is Malta issuing a tax residence certificate to the company? I am asking this because many DTA exclude companies which are taxed only for the income produced locally. In this case they tax only remitted income so not sure if it still stays inside the DTA. In theory this structure should work...

the cypriot law is tricky when it requires the person to not be considered tax resident in any other country. The implication that it suggests is that in case a person is resident both in cyprus (60days rules) and in the other country (based on internal legislation), then cyprus can revoke the...

hey guys the discussion went to other directions but I still have the doubt: a NON-RESIDENT individual shareholder of micro-company in Romania gets dividends with 0% witholding tax? in practice Mr. Red (individual - non resident ) tax resident in cyprus and receiving 10K of dividends will not...

Hi All I would like to highlight a potential idea I had looking at the Romania-US tax treaty and at Romania's local fiscal law. Let's imagine to have an online business and to work on US market (for example monetization in US) via one or more LLCs. We could imagine a structure like this...

have we already reached the point where banks reject all russians just based on passport?

it depends on the business (does it require to stay physically there?), personal situation etc... here a guide which could be useful https://static.anaf.ro/static/10/An...StabilireaRezidenteiFiscale_Editie2019_EN.pdf

thanks. In order to simplify the scheme one could simply use a Romanian company as holding and one as subsidiary. Let's say RO-H (holding) and RO-T (trade). RO-H has 100% of RO-T. RO-T is a micro-company. With a local structure things should be easier, substance also is there without big...

thank you. do you confirm that: - individuals non resident have 0%WHT; - resident companies have 0%WHT (is the 1year holding period required?). is it feasible in your opinion to have a non-resident shareholder individual receiving dividends WHT 0% and paying taxes in his residence country...

Hi all based on this document: https://www2.deloitte.com/content/d...ments/Tax/dttl-tax-romaniahighlights-2021.pdf a romanian company can distribute dividends with 0% WHT to non-resident individuals and to resident companies. Deloitte at page 5 of the document above confirms this with a clear...

thank you very much for your comprehensive explanation. very much appreciated.

with all due respect i believe you did not read my message carefully. i claimed clearly that a offshore company (incorporated outside BG) would not be tax resident in BG, while still taxable in presence of a PE (permanent establishment). Please try to read again my message since you are...

VPZ in theory did not require any presence in the country. Do you have direct info about the approach of revenue service on VPZ? because in case of disputes with the revenue service the risk is to move from 0% to 20% of taxation which is a huge difference. Based on your experience which level...