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One thing you can consider is to neither do business in Romania nor in Belgium. If your business is registered in Romania and you live in Belgium but you do your business in a 3rd country, then you can prove to the tax office in Belgium that you are not running the business from Belgium. This...

Though only internally in the country. The double tax agreement always have a tie breaker clause where taxation rights are given to one or the other country. The other country might consider that you have a permanent establishment, but in that case the income will also be divided between the...

Last edited by a moderator: Jun 24, 2021

Typically depends on jurisdiction. In some places you cannot unless Company A is doing investments, Company B is doing the correct type of business etc. The risk being that it will be reclassified as dividends and withholding tax is applied.

I'm not so sure. I'm guessing that being resident in a low/no-tax jurisdiction or a no-CRS jurisdiction in itself could trigger a bank to dig deeper to find a reasonable place to send information to.

I think you're getting some outdated advice in this thread. As quoted from your own link: Yes this kills offshore companies, and yes, that is what OECD/EU wants. You could employ someone on the ground in Dubai though to create substance. For example hire an accountant from India for about AED...

I don't have any specific case, no. When it leaks, everything will leak in one go, so you won't find a specific case leaked. I am just voicing my professional opinion on these setups. I believe they are extremely fragile. Unless you know specific details about the security of such a registry...

There is zero chance in h*ll that a "private share registry" in Georgia will be able to keep this data secure. It's just a matter of the tax office providing decent bounties. Again, the ONLY protection you have is that the bounties set by the tax authorities is currently way too low. The bounty...

I'm fine with some government functions. The most important government functions in my view are social security and free education. Defense as well, but in this time and age, defense is even more an international issue, not only national or related to taxation or government. Neither social...

@dissident the other side of the coin are the services that the government provide for you when you pay taxes. Let's assume the government is wasteful and throws away 50% of your tax euros. Further assume you make 2x the average french income, and you care only about your own outcome, not...

CFC rules are typically transitive, i.e. they work through a chain of ownership or control. As the rules are transitive, they can apply both to a company that owns a foreign company, but also the shareholders of the company that owns a foreign company, and also persons that directly own the...

I guess they mean UBO. The following is from the article, not from official documents: "All corporations with bearer shares issued are should, by November 9, 2018, disclosure their beneficial owners to the Marshall Islands registrar or convert the shares to registered shares. Any failure to do...

So absolute minimum is 8% tax?

In some way, I like this. The intermediary is a huge opsec risk today anyways, so they need to be less centralized, maybe eliminated. We might see deregulation of intermediaries because of this. For example offshore jurisdictions will allow direct and cheaper registration of companies...

Actually I'm not certain what the law says as I couldn't find a consolidated version of the IBC Act. It looks fishy in that they go back and forth like that. They are forced to open up the IBC regime for local residents and it's probably difficult for them to find lawyers that are competent. I...

For the listed company. The offshore subsidiary doesn't have to file anything in the UBO register though. How do you suggest I proceed to tell the difference between the good and the bad guys? If I can't, I must assume the effective tax in Liechtenstein is more than 100% (all my money + legal...

If non-enforcement of laws is what they are offering, then there's a whole world of opportunities out there. Maybe Congo, Venezuela, Iraq, Burundi, Madagascar and others will want to join the list of attractive dysfunctional jurisdictions.

Another country that passes legislation in panic mode. They abolish their current system, and will go for territorial taxation, but they didn't have time to actually write the legislation, so in panic they abolished their current system. The EU will not allow any type of taxation in these...

At these prices it's cheaper to buy a publicly listed company.

They are useless in Marshall Islands as well. Owners must be disclosed yearly, not to your agent, but to the Marshall Islands Registrar of Corporations.