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  1. J

    Low-Tax EU or Non EU Company Setup with Substance, Advice Needed!

    But it's also an EU member - can they actually blacklist EU member states? Usually EU law wins over local law, and CFC rules have to exempt companies in other EU countries - if they actually operate from there and aren't just an "artificial arrangement" (a shell company). Anyway, it seems like...
  2. J

    Low-Tax EU or Non EU Company Setup with Substance, Advice Needed!

    I did some googling - isn't there a whitelist of countries, and also EU countries should be exempt from this? So Malta should work, even at 5% corporate tax - provided that the company actually has substance and isn't an "artificial arrangement" (which is where it will get tricky)? If you...
  3. J

    Low-Tax EU or Non EU Company Setup with Substance, Advice Needed!

    This will be very tricky. You not only have to worry about the "managed from Sweden" part (corporate tax residence), but also the "some work being done from Sweden" part (permanent establishment), as well as the "artificial arrangement" (CFC rules) part. Probably Malta would be your best bet...
  4. J

    Low-Tax EU or Non EU Company Setup with Substance, Advice Needed!

    No, obviously not. It would be fraud. I'm surprising he's suggesting this outside the Mentor Group Gold forum.
  5. J

    Is the UK still a tax haven?

    Maybe read more carefully.
  6. J

    Scandinavian Currency Accounts in UAE?

    That doesn't sound like money laundering at all.
  7. J

    HSBC Premier Lifehack

    So in theory, you can walk into the bank, open the account and leave? No need to wait? Can you send them the documents in advance, so they can make sure nothing is missing?
  8. J

    HSBC Premier Lifehack

    If HSBC Turkey approves you, do you get the debit card right away (in the branch)? Or do you have to wait for it to arrive in the mail? Do they want proof of a Turkish address? Can they ship the card to a foreign address? I'm considering doing this, but I'm very limited on time.
  9. J

    Is the UK still a tax haven?

    Why UK? Just move to Dubai? Less stress and better weather. In case you care about tax treaties - I believe many (most?) tax treaties with the UK exempt non-dom residents from treaty benefits. This is something you should check. And I don't think your salary would be tax free - since it would...
  10. J

    Best approach for holding

    Both your scenarios 1 and 2 are very likely to be considered CFCs in France. You need to have a valid reason (saving taxes doesn't count) for not using a French holding company and you will need substance (office, employees) in the other country. There is lots of legislation in place to make...
  11. J

    Digital Nomad Perpetual Traveler + Apartment in Cyprus = tax ?

    No, absolutely not. The Cypriot TRC is void if you spend less than 6 months per year there and another country has a claim against you. You can safely assume the German tax authority is aware of this.
  12. J

    Digital Nomad Perpetual Traveler + Apartment in Cyprus = tax ?

    That would be great - like I said, then you can tell them you work from your apartment in Bangkok, for example. That would count as a PE then - even though Thailand wouldn't consider it a PE. I don't know the German rules specifically, but European PE rules in general are extremely strict, so it...
  13. J

    Digital Nomad Perpetual Traveler + Apartment in Cyprus = tax ?

    Another question would be if it's the German or the local PE rules that apply. If you live in Thailand and you work from your apartment, this would likely be considered a PE under German rules, but not under Thai rules. Sure. It doesn't sound like you have a lot of experience with how this...
  14. J

    Digital Nomad Perpetual Traveler + Apartment in Cyprus = tax ?

    If what @Don wrote is correct, then this is about income without a PE? Then just set up a PE somewhere? Even as a perpetual traveler, you'll likely want to have some sort of "paper base" for banks, so just make it the place where you run your business from and you're golden?
  15. J

    Digital Nomad Perpetual Traveler + Apartment in Cyprus = tax ?

    I'm not sure if I'm understanding this article correctly, but it sounds like it's a non-issue that could only possibly be relevant when you have income from German sources (such as rental income): https://staatenlos.ch/geld-ins-ausl...tual-traveling-keine-steuerhinterziehung-ist/ Like with US...
  16. J

    Digital Nomad Perpetual Traveler + Apartment in Cyprus = tax ?

    Can you give a quick summary of why you think this is an issue?
  17. J

    Bank account or EMI that lets a freelancer / sole proprietor use a business name (trade name) instead of personal name?

    Google says you may be able to register a company name even as a sole proprietorship, it's called "Eingetragenen Kaufmann": https://lawyersgermany.com/setting-up-a-sole-trader-in-germany/ Maybe you can use this? Not sure if there are any tax implications, you'll want to check with your accountant.
  18. J

    Curious if people would keep 500K USD in the bank or as USDC/USDT?

    Why not use US accounts? They are insured up to 250k each or so. Besides, I can't imagine the ECB would cover deposits in USD. Not to mention it would be more difficult to get USD accounts in Europe.
  19. J

    Opening a U.S. Personal Bank Account from Abroad

    NFCU is for US military and their relatives only. Someone mentioned you may be able to get an account if you are referred by another customer, but I doubt this really works.

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