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I don't understand how substance requirements can be high for a holding company. It doesn't do anything. In the courtroom, what are the arguments form the tax office? "At least 3 people should reasonably required to sit and do nothing. Owning a non-moving portolio containing 1 stock is a serious...

Also there's ongoing bank runs in Turkey because the government refuses to let the banks charge market interest rates in a country with double digit inflation. Most of their banks are probably insolvent.

Interesting! I think this option requires a bit more in-depth review, maybe a separate thread. There are significant social security contributions (in %) to be paid in Romania, but I saw in an EY report that there are maximum levels, like in Bulgaria. Also part of the social security...

I didn't understand your issue. Could you rephrase?

Transfer pricing rules. I don't think the taxman cares much for small companies, but for big companies this is a huge area.

It would be interesting to collect exemption examples from DTAs as well. I know high-tax countries without any special regimes that have specific DTAs with exemption resolutions. So you can do surprising things that are specific only for transfer of income between two specific countries.

Some other examples: Argentina: 5 years foreign-source income exempt Chile: 3 years (+ 3 year possible extension) Cyprus: non-domiciled tax exempt on dividends and interest Italy: 6-13-year 90% exemption for Italian-sourced income for professors and researchers. 5-year 70% exemption otherwise...

This is called the credit method and is by far the most common AFAIK! Actually I have been trying to compile a list of DTAs that use the exemption method for wages. Big corp only cares about capital gains, CIT etc, but when getting to your first millions, utilizing DTAs that have the exemption...

There are quite significant tax savings schemes for startups in the UK, but they might be less relevant in your situation as you are not tax resident in the UK and do not plan to make a profit.

I don't understand your sole trader issue. You can have an LLC in any high-tax jurisdiction that re-invoices a sole trader and the LLC will pay no taxes.

Two compliance things have been forced upon the tax havens and the banks: a public company registry, and CRS from the bank you use for your company.

Ukraine, 5% simplified freelancer income tax. You can do the oligarch setup with your wife tax resident in Spain and you need to carry proof that you entered Spain less than 90 days ago when stopped by police.

The parent/subsidiary directive makes it clear that no WHT will be applied inside EU. Brexit makes that more unclear, and Poland does have WHT so this is something you might want to check. What I could find was somewhat incomprehensible...

I haven't studied transfers from a branch to the head office wrt exit tax as it has never applied. I think this thread is about freelancer income, not unrealized capital gains. The exit tax would be on asset movements that include some sort of unrealized capital gains typically. Moving your...

There is some interesting research somewhat related to this when it comes to the regulation in Delaware. As you know, a lot of large US companies register there. Case law is plentiful so it's legal situation is clear. However, when researchers look at the effects of the regulatory setup in...

So their idea is to make the keeper of the registry a law firm and use attorney-client privilege to keep it confidential? I have my doubts, but if it works in the US, it could work in other offshore jurisdictions. It would probably not be confidential to the IRS, and the IRS would share with...

Not sure I understand what you mean, if the company is considered non-resident, then Estonia only adds complexity to the setup. I am talking about the owner being considered non-resident in the DTA. That does not mean that the company is considered non-resident. My point is that your legal...

Estonia has quite steep witholding taxes on most things (except some dividends), so if the DTA says you're non-resident, you have to pay the witholding tax in Estonia as well as the tax in the other country. So there might be no relief to be had.

Be aware that if you register as tax-resident in Estonia but actually live somewhere else, then the actual tax residency is regulated, not by the rules quoted in this thread, but the DTA. The DTA will make you non-resident in Estonia and liable for income tax on your dividends. In this case...

Good references, and you might very well be correct on paper. The PE issue arises for all companies though, wherever they are located. If you have a PE in the UK, you are taxed there for profits arising there. My thinking is that is given two companies that HMRC sees operating in the UK: One is...