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NO! CFC does stand for Controlled Foreign Company. It is nothing to do with exchange of information between country A and country B. CFC are rules that state if a foreign company owned by locals meets certain standards and the income meets certain standards they will force you to pay tax on...

This isn't necessarily correct. As mentioned first CFC rules and management and control (more accurately corporate residency rules) aren't the same thing so let's get terminology straight here. Anytime you're doing any sort of international tax planning you must consider: 1. Corporate tax...

Then those would still be related parties and transfer pricing rules would apply.

Ok, takes too long to explain the tax structure of each of those because they each use different structures so I'll give a brief overview of what Apple does so you can understand. First, virtually ALL major companies do apply transfer pricing in some regard to shift income. They also often use...

This is inaccurate. CFC rules are NOT what you're describing. What you're describing are management and control rules. There are also CFC rules but they are different they are what's called Anti-deferral rules.

No, your assessment is inaccurate but not illogical, it was what I figured too before I started doing international structuring. There's a specific set of rules to prevent this (contrary to comments here CFC rules likely have nothing to do with this particular structure in many cases, in some...

More reliable than Cyprus? Definitely. Now, I might be slightly biased. I'm not a huge Cyprus fan myself I've almost always found Gibraltar served myself and our clients better than Cyprus (Cyprus was mostly interesting because of how corrupt it is and the things you could get done with...

It's still possible but fairly tough and not reliable long term, I'd advise against anything in that direction.

Depends what you want it for. My experience in both Jersey and Guernsey is they want you to be whiter than white so they will deny a lot of types of businesses so what specifically are you after?

If you're going to use someone else then why Georgia for privacy? Georgia is good for privacy because it isn't part of AEOI/CRS beyond that it's not especially great (though you can get a corporate type that doesn't report shareholders). It's appealing from an operational perspective because...

I wrote extensively on Canadian rules in another thread but it's worth considering them and thinking about your long term goals. More or less I'd say what you're asking for is highly difficult and highly risky. Let's go through it step by step. 1. Privacy against government and tax authorities...

Even better, if you're a non-dom resident you should be able to get remittance based tax so you should be able to get the money into your personal name tax free or close to it so that's very appealing. Not sure your preferences but if I was in your position I'd think 19% was too high. You could...

The solution to this if you really want privacy is a properly structured trust (accompanied by good IT best practices). As far as I can tell it's the only really sustainable option that gives you operational ease, long term stability in banking, etc., flexibility of lifestyle, and good liability...

Very true, they are trying to make it as expensive to operate offshore as paying your taxes onshore so you'll just stick to onshore. You need to anticipate these changes and build something that's sustainable so your energy is focused on building your business not trying to maintain and rebuild...

UOB, OCBC, Standard Chartered, etc. etc. etc. Then you can bank with that company in Singapore or elsewhere as well. Labuan as far as I'm concerned currently has some of the best banking options going for a country with very low tax. Consider what are your alternatives going to be? HK has some...

Don't confuse zero Cyprus tax or zero HK tax for zero tax in your home country. That's always been and continues to be the big problem. If you live in most developed countries avoiding their tax isn't achieved just by forming a company in a low or zero tax country or everyone would do it and...

There is a business though and that's the people. A one man show isn't really a business and so long as you're a one man show from a tax standpoint you'll be taxable wherever you are more or less. The thing is though most online or digital businesses use contractors, etc. and the larger the...

Be careful here if you're dealing with international banks. For example, most of the banks in Montenegro are foreign owned and it's normal that everything they do flows through their parent in say Austria so you need to be aware not just of the local presence but how the foreign parent deals...

This is a very good question. My guess is this is designed to go after something like the Cost Sharing Agreements Apple is so fond of using, sale of IP can't be an issue so although you might have issues simply moving the company (then again who is going to come after you, which jurisdiction?)...

Poland is a super big hassle to deal with, not recommended if you can avoid it. Things there are expensive and slow with lots of nuissance. On top of that forming a company in Poland on its own doesn't free you of tax elsewhere you need to actually look at the substance of the business. If...