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  1. Don

    Corporate tax residency rules - using Jersey as an exxample

    A foreign branch is not a separate legal entity from its parent company. Instead, it is an extension of the main company operating in another jurisdiction. This means the parent company does not "own" the branch the same way it would own shares in a subsidiary. The foreign branch is part of the...
  2. Don

    Question offshore company for investing in crypto/stock market

    It could be tax-free in some instances. You need to consider your personal tax residence, the company's tax residency, the company's PEs (e.g., where the trading is happening), and potential tax exemptions (whether the income is exempt from tax on a personal/corporate level). Why would it not...
  3. Don

    Estonia Corporate Tax: to pay or not to pay?

    Yes, the very meaning of PE is that only locally sourced profits might be taxed. Having a registered PE of a foreign company could lead to following scenarios: 1) PE is registered but not treated as a PE for tax purposes. This can be the case when PE registration is done only because for...
  4. Don

    Estonia Corporate Tax: to pay or not to pay?

    Im just assuming that the US LLC disregarded for tax purposes is controlled by an individual (it doesn't have parent entity that is a Estonian company).
  5. Don

    Estonia Corporate Tax: to pay or not to pay?

    Interpretation of an interpretation via a Google translation can be misleading. It's not "related parties" but correct is "associated enterprises" Here is the relevant provision from the law:
  6. Don

    Estonia Corporate Tax: to pay or not to pay?

    no, in Estonia, it is not possible in such a context for the entity to be considered a CFC because there is no such applicable law. However, foreign entities could be taxed as PE-s. PEs are taxed at zero until profits are deemed withdrawn from the PE (e.g., repatriated to the place of...
  7. Don

    Estonia Corporate Tax: to pay or not to pay?

    CFC rules apply only when there is a resident company that owns shares in a foreign enterprise.
  8. Don

    Corporate tax residency rules - using Jersey as an exxample

    no, in such case its not Jersey company but a non-resident foreign company operating in Jersey as a branch if the foreign entity doesn't tax the profits arising from Jersey, and distributing that income to you is also tax-free, then no tax What's interesting is that it's possible to have...
  9. Don

    Corporate tax residency rules - using Jersey as an exxample

    You can operate as a Jersey branch of a foreign company. Provided certain conditions are met, it might result in overall zero or close to zero taxes.
  10. Don

    Argentina - Pros Cons

    Relax; they are not trying to injure you or kill you; they are just trying to get your valuables. So don't flash around with an iPhone, and cover yourself if you have a youthful, healthy body ripe for harvesting.
  11. Don

    UAE - Today

    Depends on your situation. For some, Bahrain could be perfect.. for others, it's not an option. For some, UAE is still good. Saudi Arabia could be great for headquarters.
  12. Don

    Free residence permit on the table: Mother Russia welcomes you

    I'm not negative about the governments, but I am pessimistic about certain policies. Particularly, I'm not in favor of communism, or crony capitalism / plutocracy / corporate oligarchy. I guess many users here represent family-owned businesses (SME enterprises with less than 50m annual revenue)...
  13. Don

    UAE - Today

    Right, UAE is definitely not the same jurisdiction it used to be.
  14. Don

    UAE - Today

    Indeed, it doesn't provide many advantages and no benefit from a corporate tax perspective. Sometimes, it might be beneficial to access certain tax treaties, better regulations, etc.
  15. Don

    UAE - Today

    Under the UAE CT Law, companies and other juridical persons that are incorporated or otherwise formed or recognised under the laws of the United Arab Emirates will be considered resident persons. This covers juridical persons incorporated in the United Arab Emirates under either mainland...
  16. Don

    UAE - Today

    Actually everything is announced by https://mof.gov.ae/united-arb-emirates-ministry-of-finance/ Not all will pay tax. It depends on the type of income and how much income the company generates. Charities might be exempt, for example. E.g., if your RAK offshore company has a permanent...
  17. Don

    UAE - Today

    All businesses (including free zone companies) with their first financial year on or after June 1, 2023, must file for corporate tax registration in the UAE in the form and within the timeline set out by the authority, except in cases where the Minister prescribed otherwise. Furthermore, any...
  18. Don

    Free residence permit on the table: Mother Russia welcomes you

    Police seems much friendlier in Russia than in USA imo
  19. Don

    Free residence permit on the table: Mother Russia welcomes you

    How are you free to move if you have to pay extra to move? That's not freedom, and if you don't move you have to still pay "pizzo", otherwise you will die of starvation, be locked up, or killed EDIT: by "Government" I actually meant "Mafia" (original source...
  20. Don

    Free residence permit on the table: Mother Russia welcomes you

    in many countries its not free to move out..its called exit taxes. Russia's neighbour USA taxes you only for having citizenship

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