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I wouldn't call a LLC similar to this setup. The UK Ltd is not disregarded for tax purposes, but pays no taxes only because the tie-breaker clause in the DTA assigns another country the taxation rights. If you then start doing business in the UK, you might be tax resident in both countries. A...

https://news.bitcoin.com/russia-law-criminalizes-buying-bitcoin-7-years-jail/

Yes

There is no witholding tax on dividends. What you pay next is up to your own jurisdiction.

Yes I have experience running a company like this for more than 10 years. I have only used a UK Ltd. This is quite advantageous in EU and actually in most countries. The reason is, most DTA agreements include a non-discrimination clause which means that a foreign company should not be treated...

Yes in theory it should work, but say you want to pay dividends from your Estonian company with a branch in Cyprus. What sort of papers do you need to fill out to prove your situation? Alternatively, let's say your company is a german GmbH and you need to file full branch tax reports in Germany...

I haven't checked, but will a Romanian micro company allow company owners? Often these structures require one owner, and that it be a physical person.

Treaty non-resident means exactly what you say. In a standard OECD tax treaty, there is always a definition for where a company is located. What the UK says is that if, through a DTA treaty, the company is located in the other state, then it's a "treaty non-resident" and pays no taxes in the UK...

You typically do this sort of setup with UK companies, not Estonian companies. With your proposed setup, you need to pay both Estonian tax and Cyprus tax, or you need to at least create dual sets of accounts. With a UK company instead, you don't need to file anything, as if nothing happens in...

No witholding tax will be paid in Cyprus as per the EU parent-subsidiary directive, but corporate tax will be paid. In most jurisdictions, no tax will be paid by the parent company on dividends (google holding regime).

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Except that Norway is a hidden gem of a tax haven. I helped a foreigner setup in Norway, and he paid 3% last year on €50k and because of Norway's DTAs, fully exempted income that was. As I said earlier in this thread, high tax jurisdictions have high tax deductions and incentives!

USDT and other stablecoins don't fluctuate. /more words words words

Exchange into stablecoins. Chinese residents bought $10G of USDT last year alone.

If it is tax resident in another country due to the tie-breaker clause in the DTA, then the status is "treaty non-resident". So it is non-resident for tax purposes. INTM120070 - International Manual - HMRC internal manual - GOV.UK My question is: how does a bank know if this is the status of a...

Remember that the strict currency control in China, and everbody in China trying to get money out, means that you should have no problems getting a good exchange rate. Indeed, for USDT, there's a premium paid in the OTC market. If you exchange into USDT and transfer that to your contact, you...

Does anyone know the legal implications of receiving money and paying for an invoice for company B through the bank account of company A? Company B has lost its bank accounts and was in need of doing a trade. Company A did a deal with this company to represent them in this 100% legit deal. What...

If my UK company with existing bank accounts becomes treaty non-resident, how will the banks know?

I think a PE in the 3rd country would be highly unlikely in that situation, given that there is not a single person permanently working there. Just don't make it too permanent. OECD's DTA article 5 defines this, so we can look at the commentary: Page 53...

That's news to me. I don't think that's common. For example article 15 in the standard OECD tax treaty typically lets an employee work in a country for 183 days without paying income tax. In practice, I think such laws are mostly toothless since the DTA will render such laws moot. I agree that...