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You're right, i missed the boat with this one. I thought HQ = final holding while isn't always the case.

I already told you how, when UAEco receives dividends from subsidiaries and to receive dividends from subsidiaries, subsidiaries have to make profits. That's why you don't start with UAEco from day one. No company has headquarter from day one, you build it overtime. If you want to start with...

That's defintely true, i personally always had terrible experiences but the point here is that headquarter's job is to save subsidiaries money, not the reverse. You want to ave time and resources? Develop some kind of SEO software by leveraging a tool like N8N with RPA and license that SEO...

Yes but this surely isn't intented as a way to shift profits by reselling services at higher cost to subsidiaries because it wouldn't make sense for the subsidiary to pay you more than would have paid to the unrelated party. In a genuine situation and if the quality of service is equal, the...

If subisdiaries buy directly from headquarter it means that headquarter bought from those indian SEO agencies first to be able to resell to subsidiaries so headquarter acts as an intermediary. I could be wrong but procurement service would be if UAEco negotiate a deal with SEO agencies and then...

Headquarter is essentially a final holding that receives dividends from subsidiaries so one of its job could be to reinvest income to support financially a subsidiary in a new area. They made it very clear from the official definition that headquarter can't do any kind of operative work but...

UAE company should act as connector only between related parties. Since the official definition says "Headquarter services to Related Parties" partner firms are outside the scope of the headquarter. Headquarter only deals with subsidiaries providing management, financing and so on. The...

Those are not related parties.

If you are Panama resident CRS will report to Panama but even if it's reported to passport country who cares since you should not be tax resident there anymore.

So he is basically giving an option to all those UK non-doms that don't know where to move to.

According to my personal database the next will be Poland

Awesome!

@littlerabbit it's your turn now :)

I wouldn't do that, using the resident non domiciled setup allows you to stay flexible and move in the event Malta will update its tax regime as they already planned to do.

Which transfer pricing checks are you talking about? :cool: https://taxsummaries.pwc.com/malta/corporate/group-taxation https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0651 If he develops his own apps then the IP is internally developed.

True, and it's not a territorial taxation system, it's "non-dom" for companies. I know but we can be smarther than that. I mean that if @littlerabbit as owner of IP licenses that IP to a company resident non domiciled in Malta he could get 95% of the income generated by the maltese company...

If that was the case you could remit foreign sourced income tax free. In Malta you could remit only capital gains tax free, any other foreign sourced income, if remitted, is taxed at income tax rates. I've never seen a serious business built on such a fragile foundation. If you do the math...

Because is the most efficient way i know to pay 0% tax with a legit setup. If you know other ways this is a forum, please share your knowledge, i'm all ears :) And BTW same setup with a twist could be to license IP to Maltese resident non domiciled company that will distribute apps on...

Book a paid consultation with the guys who wrote the article about resident non domiciled companies describing the propsed setup and report back their answer. Their feedback is worth more than money, at least for me. IMHO it could work because i was told that the key is where the work is...