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  1. Don

    It is now legal to confiscate your assets in the west - movie

    Lets watch and talk: https://rumble.com/v517z08-stop-it-great-taking-film-trailer.html Anyone read the Great Taking or seen the documentary? It describes the details of how it is now legal to confiscate assets in the west. https://thegreattaking.com/...
  2. Don

    Offshore Shell company in philippine feasible?

    Im not an expert on Philippines myself but I know someone who has extensive experience on the matter. This kind man wrote an comprehensive guide for our circle about some of the ins and outs of life and business in Philippines. Ill copy some bits that could be relevant below: Incorporation in...
  3. Don

    Offshore Shell company in philippine feasible?

    Philippines is actually a great country to run an offshore company from if you are based there, but I would stay away from incorporating locally for anything else than simple staffing company to pay some local tax. Ive seen some cases of 0% tax setups for 30+ years :) living full time in...
  4. Don

    Suitable structure/residency for active trader (Stocks, futures, options)

    I recommend consulting a professional if you choose anything else than trading on your personal name, which might be the simplest and most cost efficient way. There are more brokerage options now in UAE - a few months ago IBKR opened in DIFC...
  5. Don

    Suitable structure/residency for active trader (Stocks, futures, options)

    It could be worth to set it up under an US LLC, but you would need to take trips to US to open a bank account. US brokers have certain advantages. And don't forget Indians make up the majority of the population in the UAE. UAE indeed has easy options for residence.
  6. Don

    The new 2% tax in Estonia even for not distributed profits (No more 0%?)

    It depends on the situation. Changing the legal form and headquarters only might not bring about any tax events. Its more important what happens in substance than form.
  7. Don

    The new 2% tax in Estonia even for not distributed profits (No more 0%?)

    Once you have merged the company or relocated to another (EU) jurisdiction, then only the local PE can be taxed, doesn't matter if SE or not.
  8. Don

    The new 2% tax in Estonia even for not distributed profits (No more 0%?)

    It will. If only it was so simple. Otherwise noone would pay dividends and everyone would "withdraw profits" by just relocating the company. However the cool thing about it is that you can defer paying the exit income tax over 5 years in certain cases.
  9. Don

    The new 2% tax in Estonia even for not distributed profits (No more 0%?)

    If as a result of the merger or redomiciliation the assets remain in the PE of Estonia then no tax is paid on the merger. However, the foreign company PE in Estonia pays tax on its profits (the 2% defence tax on Estonian sourced profits). Estonian PE-s of foreign companies don't have to follow...
  10. Don

    The new 2% tax in Estonia even for not distributed profits (No more 0%?)

    The tax is based on profit. If there is no profit then no tax. Depends on your activities. Development costs for example are normally not capitalized.
  11. Don

    The new 2% tax in Estonia even for not distributed profits (No more 0%?)

    Not much to add to what has already been said. No doubt its a stupid policy. Estonia certainly loses its main benefit as an offshore jurisdiction. Dividends from subsidiaries or foreign PE-s are still not going to be taxed though. Merging or closing company wont really help to save on tax...
  12. Don

    Best way to set up company to charge customers Tax Free?

    A dutch cv is not a legal personality. Its basically just a contract, and it can not own assets or enter into contracts. Regardless its a tool that can be used in tax planning, but its only one part of the equation, as you would most often need to involve legal entities.
  13. Don

    Tangem hardware wallet

    Ordered this wallet as well. Mind sharing what wallets you use for cold storage? I think we are missing a thread for "best cold wallet" @JohnnyDoe @rss @void
  14. Don

    Anonymous (or with nominee) company in Europe

    You can look into silent partnerships. This is a legit way to do business anonymously, while you have someone acting as a front for your business.
  15. Don

    MALTA/DUBAI/HUNGARY/CYPRUS - whats the best play in this scenario?

    Foreign company tax residence will be assessed based on a double tax treaty article 4. "Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by...
  16. Don

    Optimal Tax Setup for Fully Digital Professional Services Firm

    No, some people are genuinely nomadic, and some don't have such high risk of dual tax residency. It boils down to individual circumstances. There are no universal rules in that sense.
  17. Don

    Optimal Tax Setup for Fully Digital Professional Services Firm

    You should build some economic substance in order to be compliant with regulations and avoid tax risks. Look into ATAD, GAAR, CFC rules, Not suggesting anything, but I think its a nice feature.
  18. Don

    Possible to avoid CRS with USA setup?

    Heres how: https://www.justice.gov/opa/pr/cour...eking-information-about-dutch-residents-using
  19. Don

    Optimal Tax Setup for Fully Digital Professional Services Firm

    Yes, I know of practical cases with the same setup OP was describing. UBO was staying few weeks per year in Malta at best, yet was able to obtain Maltese tax residency.
  20. Don

    Optimal Tax Setup for Fully Digital Professional Services Firm

    Regarding missing anything, you should not manage the holding company from Malta but hire a local director for the holding. In Malta, taking out loans from your company is also possible.

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