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In fact, after looking into it more deeply, even the use of a nominee director and a nominee shareholder is not a protection against the CFC rules, since they aim to identify the ultimate beneficiary owner, which is you, regardless of if you officially direct or own the company. If you don't...

I wonder where's the catch with these UK LTD nominee services. Do Western governments really allow such anonymous setups facilitating CFC and POEM avoidance to exist right under their noses? It's hard to believe.

Alright, thanks for the info.

ok. How do you control the holding company then? How do you ensure that they won't transfer all the subsidiary's capital to them? Sorry but I thought you need to have some kind of a control over the holding company even if it has a nominee director and shareholder.

An UK holding company is an interesting option, but in case of need I can't move to the UK and create an economic substance there cheaply. btw. what good for is a nominee director and a nominee shareholder when I will still have to own at least 50% of the company, which makes it vulnerable to...

As I wrote I'm not going to distribute any draws. I like to have a low cost an option if I need to make it an operating company, if there's a need to create an economic substance. For example if within a year some new information shows up that makes the original plan impossible. I wrote...

3% revenue tax or 1% if you hire at least 1 employee in case of need, easier to create an economic substance, can be made a legit company due to proximity, membership in the EU, and a low cost of labor, and doesn't attract attention like a tax haven jurisdiction not sure if it's a good idea to...

It can notify country A all it wants if there won't be anything to be taxed. Yeah I will verify if Romania really sees an LLC as an opaque entity. I've searched in Romanian with google translate and couldn't find anything. The Romanian tax advisors were surprised by the question too.

Anyway, in fact, there's no need to hide, I guess. Let's say the holding company will be incorporated in Romania, I will be the director. The company will have no income, will pay no salary or dividends. Its sole purpose will be to hold the LLC, it will be indicated as the owner of the LLC on...

US banks don't report this. And don't collect foreign tax IDs.

I'm again here today with another setup. I live in an EU country A. Lets say there will be a Delaware LLC which will sign contracts with clients, collect payments etc. This LLC will be owned by a holding company incorporated in a low tax jurisdiction, ideally non-cooperating, like the Cayman...

Not sure how you can stay under the radar. I think foreign bank accounts are being reported automatically under the CRS, so if you have a residency in Germany and you open a bank account for your Romanian company it will be reported back to Germany, no? Also I think you have an obligation to...

How does it work exactly? Did you report it to your home tax authorities? Or did they find out? How do they decide what part of the profit is taxable where?

Why do you recommend Romania, Bulgaria or Cyprus for incorporation if he wants to spend a substantial time in Germany? Wouldn't that give Germany an opportunity to claim permanent establishment of effective place of management of the company? How can he avoid being appropriated by Germany?

I got my EIN in 2 weeks. Filled the form, faxed it to the IRS. It was very fast, I was expecting at least 4 weeks, a few months ago it was 2-3 months due to Corona.

Well that's good to know. I used to describe the situation in the first e-mail. But it's not dodgy or illegal, in fact that's why I was contacting them, so that I don't break any law. I asked them for a quote for an advice in this situation, not for the advice right away for free. So I don't...

Thanks. Unfortunately lawyers don't want to talk to me. I've contacted tens of them, got about 5 replies, 3 of which were "sorry we don't do this", and 2 were free mini advices that helped a bit but don't give me a guarantee. Not sure if this is normal or if I'm doing something wrong.

Only a residency of the owner / manager is enough? I thought it's about the place of effective management and permanent establishment.

Thanks. But how can a country A demand anything when no work or management in the name of the company B is being performed on its territory?

I reside in an EU country A and I want to create a company in an EU country B. This company would outsource all its work, so that the only activity for me to do is management. It would have an office in the country B and I would travel there once a month to manage the company there. The work...