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I ve explained 4 times... no bank transactions for dividend so no money in UK bank account of the holding. Accountant make all the paper for the refund... such as letters meeting of the directors and shareholders where the shareholders declare that the holding got dividends and the request to...

on the documents filled by the accountant there are declaration of dividend distribution! it's all clear for maltese CFR that i'm director of both company

my accountant send all the request and documents for the refund, after that CFR send her a confirmation, after that i pay taxes to Malta and than in 15/20 i ll get refund

exactly @GrumpyMess and @Martin Everson i think so! btw thanks for your informations

yes 100% own of the uk ltd today i will have a call with few accountant, let's see... but all accountants ask to the CFR how to proceed. my accountant too work in this industry from 15 years, she is confronting with other colleagues about tax matters so i think this is how malta work. i never...

Yes could be but if you think more deeply, we are talking about an holding , how many decision the Director of the holding take annually??? 2/3 flights to UK maybe? So in fact company is not managed and controlled in Malta! And in Fact maltese company is holding by foreign shareholder.

As my accountant made last year the refund is made directly on the bank account of the malta ltd or to the beneficial owner resident non dom... last year i've got smoothly in this way let s see this year... Btw tomorrow or Monday i'll get a call from csb about cfc rule, refund 6/7 etc...

Or your Malta accountant just filing zero returns for your UK holding company as you said below in which case no dividends are ever paid from Malta company right? no dividend to Holding correct

Few reliable bank of porto rico or Georgia? Porto Rico will become CRS?

yes i'm resident non dom in Malta

ahahah, you can ask directly or you can pay law firm for advice... if you are interested!

If you want i can share all url of the best maltese law firm where they wrote ther foreign company with management and control in Malta will be taxable in Malta only on the income arising in Malta and income arising outside Malta only if they are remitted in Malta.... It's possible or it's like...

Please post also the source...

With cfc rules They have applied some threshold as i wrote... csb aswell wrote same thing : No you need to meet one of the point above! Please read well there are 4 points please read well, they use OR and not AND ( this is very important) to go out from CFC rules The CFC rule shall not find...

Ltd malta hold by ltd uk... very simple structure my accountant told me better structure without nominees... i'll update you

So basically to be sure that your foreign company that you manage and control from Malta are not taxable with 35% of maltese corporate you must be sure that 1 of the following point is met 1) the tax rate that your foreign company are paying is equal or more than 17,5% or 2) you own less than...

But from 1 January 2019 with ATAD there is also CFC rule that it's more strict... With CFC rule your foreign company's income could be included in the tax base of the Maltese resident entity But there are few conditions and threshold: It's considered Controlled Foreign Company when the 2...

I don't know about tax free company offshore, you should ask to one of the auditors that i've shared. The point is that the domicile must be in the foreign country where the company is incorporated.

Yes

Albania will become crs on 2020? At the moment is not crs yet...