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If he sells his shares to the CY company (and if his home country successfully claims his tax residency for previous years) he could be liable to pay exit tax . What do you think @Marzio ?

just 50% shareholder, not a director perfect - that's what I had understood from the DTA but was not 100% sure From a Cyprus perspective things seems clear - Spain is my main concern. I gather that what makes sense having mentioned the above is to find a tax advisor in Spain? Apologies for...

I am a 50% shareholder of a private company in Spain yet my tax residency is in Cyprus. In the event the company pays a dividend, how would this be taxed? I have read the DTT but it is still unclear