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The plan is to get a second residency in HU, use a HU company as the operation company, get a HU tax id and pay myself salary without the need to declare it in the home country thanks to the DTT. After a few years, when it's time to cash out, make it a subsidiary of a CY company, establish a tax...

WHT to individuals is always paid according to many DTTs. But if an EU parent company owns it, for example in Cyprus, it's 0% on both sides. If you reside in Malta and pay yourself dividends from the Cypriot holding company, it's 0% in total. With base erosion on the Hungarian side, it can be...

No. But incorporation services will offer you this option. I don't really care about where it is domiciled, just that I won't pay the tax.

You pay 9% CIT to the state, and then you pay 0-2% to the municipality too. If you domicile it in the right place, you can reduce it to 0%, so you'll pay only the 9% CIT. It's the same in many other countries.

Since you pay tax on revenue, i.e. can't reduce tax base, it too is effectively a tax on turnover. So in total 6-8% no matter what. You can't reduce it. In Hungary the ceiling is 9% but on profit so you can reduce it. If you register it in the right location you can pay 0% local tax. Therefore...

Yeah, so you'll pay yourself minimum wage, no dividends, all money will stay locked inside the company while you'll be struggling.

Thanks. I want to point out that it's 6% from the revenue, not profit. Since you need to employ someone, effectively it's more than that. An attractive alternative is a company in Hungary that pays 9% on profit. With base erosion, it's possible to achieve and surpass Romanian levels.

I found this: Online cégalapítás 29990 Ft-tól, székhelyszolgáltatás, országosan 20 irodában They're not the cheapest but they replied within minutes and in English. It'll cost roughly 190 EUR for a formation and a virtual office for 1 year. Compared to how it is in other countries, not bad.

Yes it does. It didn't until 2017 precisely because of this, but the IRS created an exception in this case to comply with international treaties and information exchange, so that the US can't be labelled as a non-cooperative jurisdiction enabling tax evasion anymore. For this particular IRS...

Do you know any good company formation services in Hungary?

Thanks. I wrote them an e-mail a few days ago in English but they didn't reply. Seems like communication with them would be difficult.

Anyone knows any solid incorporation service provider in Hungary? So far what I've found has been terrible, both in terms of quality and price. I've searched both in English and Hungarian. Last edited: Jan 8, 2022

For a holding company it changes nothing. Dividends received from a subsidiary in an EU country continue to be taxed with 0% both in that country and in Cyprus, and paying dividends to non-residents also remains at 0%. They're not taxable by the CIT.

What are you talking about?? This is about not declaring your LLC, i.e. tax evasion.

Yes, many countries don't seem to be interested in what the IRS is offering them. For now. But your freedom and financial wellbeing is always just one click away from being destroyed. Last edited: Jan 5, 2022

Of course you'd need to have a second home in the country of incorporation. Once you pay yourself there, you'll get a local tax ID, which you can use to open bank accounts, brokerage accounts etc, without the first country being notified through the CRS. If there's any tax residency information...

If I want to keep tax residency in the current country while having a company in another EU country, the solution is to create an economic substance there. But it seems like it's a problem to hire someone if he/she already has a job, because of limits on work hours. Due to double tax treaties...

That it has been ok for years doesn't mean taxes and penalties can't be applied retroactively. The IRS raised fine for incorrect filing from $10000 in 2017 to $25000 now. That's an indication that they do care about this. If your country wakes up one day and decides to go through all what the...

If you'd read the FATCA agreements and the TIEA agreements between the US and your country you'd realize that in fact everything about your "anonymous" LLC is being reported automatically to the country you indicated on the IRS form 5472 as a place of where the business is conducted and as a...

Obviously he's trying to not to pay taxes at all, thinking just because the LLC is transparent and non-ETBUS in the US and Cyprus doesn't tax non-dom dividends he can achieve a nett 0% tax. The reason why it won't work is because by running it from Cyprus he's creating there a permanent...