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    Start a company in France instead of Ireland/Hong Kong?

    It depends on the legal form of your company, whether the profit has been paid out to you via dividends or is still in your company, wether you keep the company with its assets in France, how long you have lived in France during the last 10 years and whether the country you move to is within...
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    Start a company in France instead of Ireland/Hong Kong?

    If you intend to make only 5 figures there's no point creating a LTD company in HK or Ireland, especially if you don't want to live there. In France, you can have the "microentrepreneur" or "autoentrepreneur" regime with lower social contribution and income tax rates. The exit tax only applies...
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    Start a company in France instead of Ireland/Hong Kong?

    Yes, you will need substance in Switzerland (an office) and be able to prove that you commute regularly to your office. But if you live in the area there's no problem doing your business in a neighbouring EU/EEA country since your PoEM is there. It's a constitutional EU right. Don't understand...
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    Start a company in France instead of Ireland/Hong Kong?

    Dividends are progressively taxed as income in Switzerland (although assessment basis is only 70% in GE) while there's flat tax in France. Then, there's wealth tax in CH. Real estate is 2-3 times more expensive than across the border. Social contributions depend on where you chose to have your...
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    Start a company in France instead of Ireland/Hong Kong?

    Not necessarily. Depends always on your situation. An interesting setup is to create a company in Switzerland and live in neighbouring French border regions as Frontalier. Then you pay as low as 10% CT in CH and 20% on dividends in F if your health insurance is in Switzerland. On a low salary...
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    Parents' home as "permanent home available"?

    This would be a question for a specialized tax lawyer who understands the tax law of your country and the country where you want to do your business. IMO just having a parents home in one place doesn't make a case for tax residency without formal proof such as a written rental contract. However...
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    Parents' home as "permanent home available"?

    Having a business in country A is usually a stronger case for centre of vital interest than having a permament address in country B according to OECD practice. That is even more the case if you spend <183 days in country B and if you don't have a rental contract or don't own a home there. There...
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    Recommendations for Cyprus Company Service Provider

    I would recommend hiring an "independent" lawyer who advises on and oversees the entire company formation process. I have made bad experiences with a large CSP in Cyprus. They told me that I could operate a company offshore in Cyprus for my business (stock trading) with myself as director and...
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    Can you recommend a stock trading investment platform (for users worldwide)

    If you got rejected from IBKR, you could try a so-called white label partner partner of IBKR to get access to their platform. These are separate brokerage entities doing their own onboarding of clients but using the IBKR platform. But you need to distinguish white label partners from so-called...
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    Can you recommend a stock trading investment platform (for users worldwide)

    You can find a list on brokerchooser.com for your country of residence.
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    PE rules for Swiss or US Corporation

    You are citing the OECD model convention. https://www.oecd.org/tax/treaties/35363840.pdf1) Not all EU countries are member of the OECD and have implemented this model convention 1-to-1 in their tax legislation and their DTAs. 2) In order for a business to have a permanent establishment in...
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    PE rules for Swiss or US Corporation

    Of course, it will be considered tax resident in Switzerland if it's incorporated there. But it does not necessarily mean that it will be considered tax resident in another EU country as well f it's managed from there and/or the physical person owner has his permanent tax residence there. Some...
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    PE rules for Swiss or US Corporation

    Whether a company incorporated in country B is considered a tax resident in country A because it is managed/owned by a resident in country A depends on the tax law in country A, the substance in country B, whether the company is controlled/managed by a physical or legal person and the DTA...
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    PE rules for Swiss or US Corporation

    Depends on the country where it is managed from and whether the owner of the company is a legal or physical person. Cannot be answered in general.
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    How do you avoid border controls in Romania, Bulgaria and Cyprus when entering from other EU countries?

    There are lots of hiking trails that cross the border and are not controlled (especially at mountain peaks). For Cyprus, you would need to have your private yacht :D
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    Digital Nomad with dual citizenship looking for new Tax Residency away from UK

    At least in Paphos rents have increased massively by more than 100%. That was one of the reasons why I have not chosen Cyprus although I initially wanted to move there. 2 years ago, you could rent a nice new-built villa there for 1000 €/month, now it's 2000-3000€. Also, it gets more...
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    Digital Nomad with dual citizenship looking for new Tax Residency away from UK

    check nomadlist.com . There you can rank the best places for nomads according to your criteria. In Bulgaria, you can get a tax certificate even if you spend less than 183 days but you need to have a permenent residence there.
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    Correct setup for cryptotrader?

    It all depends all on your lifestyle preferences. For some it might also be considered boring to spend most of the year indoor in an autocratic sharia law desert country with the air conditioner running all the time. Zug is located in the middle of the alps with lots of lakes nearby, so it can...
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    Htf trading bot

    Why should they not accept it? In general, they are earning their money with commissions or bid/ask spreads. The more you trade with them the better for them. But there's an exception if it comes to CFD brokers which act as a counterparty to you (if they don't hedge their trades with you...
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    Correct setup for cryptotrader?

    No, one of the big advantages in Bulgaria is that " CFC rules do not apply to taxes of individuals. If the company is controlled by a physical person who is a Bulgarian tax resident, the Bulgarian Controlled Foreign Company rules do not matter.". CFC rules are currently only applied if there's a...

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