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  1. M

    Nominee Director Substance thought process.

    As mentioned earlier it depends on the situation and as a first layer a nominee director will diffuse risks of transfer pricing, taxation etc. If tax authorities suspect something and start to look further into it they will dig deeper and will ask quite some information, such as : - who...
  2. M

    Question How many of you have been asked at borders where your tax residency is?

    Hong Kong Singapore could be definitely on the list. A big surprise as I crossed through Hong Kong probably over 100 times and always believed this could only happened to people that looked suspicious or came from a third world country. Was my first entry after covid saga for years. Better if...
  3. M

    Question How many of you have been asked at borders where your tax residency is?

    Why would they ask this when you cross a border. These are immigration agents not tax agents. I have had the experience for an unknown reason being put aside at a border and asked hundred of questions while having to show my credit cards, login on company bank account, give my local friend...
  4. M

    Company structure for real estate investments

    How do you come to this conclusion? Taxation on profit has nothing related to loan, before making investments I would recommend to understand the basics of corporate tax and accounting. The only thing you can deduct from your income profit is the interest rate you will charge to the...
  5. M

    Does Payoneer (setting up as payment intermediary) report to Tax authorities?

    Personal experiences don't always reflect majority experiences. There are many in Asia that use payoneer as it is the standard recommended EMI for non EU, non US corporations that do ecommerce in Europe, US etc. The service provided is different according to your jurisdiction, some countries...
  6. M

    High asset value and sales company (HK / US?)

    Getting a corporate bank account in Hong Kong without any link to China mainland or Hong Kong would be a challenge. Using EMI is no option at all. As mentioned above if he lives in Turkey, operates in Turkey and has customers in Turkey he is liable to Turkish taxation. Even Turkey is not like...
  7. M

    Global taxes/ompliance consultant recommendations?

    You better specify which jurisdictions you reside, where your abode is (even you are a perpetual traveler most stay for a long time in one country or have still connections with their country of citizenship) , your citizenship, where you will incorporate and operate businesses from. From my...
  8. M

    Circumvent transfer pricing restrictions by using multiple companies?

    Company B will be the shareholder of company A and at the same time will also bill company for an amount equal as 75% of the profit? At the same time the shareholder (co B) will also receive dividends. This is for sure already asking for an investigation by tax authorities in the jurisdiction of...
  9. M

    Wise is now CRS compliant

    As mentioned above, a transfer above 10k will be automatically reported by a financial institution, which doesnt mean you get questions asked or have any risk. Daily there are millions of such transactions of 10k to millions, so nothing special here. It is better nonetheless to keep your...
  10. M

    charging company in eu from company in faraway island that has 0 % tax

    This is correct. Even by using a nominee director this will be easily pierced by tax authorities 1) you reduce profit with billing form a tax haven. What services and proof of services you can provide? 2) anything billing from a tax haven will increase exponentially the risk of having tax...
  11. M

    Wise is now CRS compliant

    Transaction above 10keur will be reported to your country of residence. Some Belgian citizen created a fee months ago a new personal wise bank account and after one month it was already linked and visible to his online government account where all bank accounts and 6 month ending balance of...
  12. M

    Non Tax Resident in Spain or France with low substance offshore Company

    Totally agree on this. Too many people in this forum believe getting a residence certificate somewhere, spending there 2-3 months is enough to make you non resident in another country. Only thing it might achieve is that it also makes you a resident in that country. If you spend most of your...
  13. M

    What are your single highest transaction using EMI like wise ?

    Personal or corporate account? Corporate accounts are under much less scrutiny to transfer large amounts then personal accounts of they have gone through some KYC. Corporate 100k usd transfers no problems after going once or twice in the beginning providing some invoice. Anything above 100k...
  14. M

    Non Tax Resident in Spain or France with low substance offshore Company

    I don't believe hotel info is shared with tax authorities, but who knows nowadays with all data sharing and mining. Better be safe than sorry. You can also use a debit / prepaid card on someone else their name. Let someone else spend with your card in your claimed country of residence in...
  15. M

    Digital Nomads, Biz owners in Bangkok

    Even the residential address indicates Thailand it could be still different with the permanent residential address the bank has on record for CRS purposes. I recall that the bank asked Skenners to provide a permanent address in his country of citizenship, this is normally the address used for...
  16. M

    Digital Nomads, Biz owners in Bangkok

    You have a German passport so you are a German citizen in this case, ofcourse you can be mapped by German tax authorities unless there are many persons with the same name. It would be interesting how tax authorities use and analyze the information reported, nonetheless even without a TIN...
  17. M

    Non Tax Resident in Spain or France with low substance offshore Company

    Should be DTT instead DTT It is recommended to use the above approach to avoid spam and leave less traces, especially if you don't want them to find out where you stayed and pay in cash or an unknown card. On the other hand hotel bookings are not something I believe tax authorities can have...
  18. M

    Non Tax Resident in Spain or France with low substance offshore Company

    You are looking at taxation by each country from a wrong perspective, these three countries will not "fight" against each other to proof you have to pay tax in their jurisdiction and not the other country, they don't care about other countries. All three if they believe they have the right to...
  19. M

    UAE clarification of Freezone Qualifying Income

    This is xoredt This is indeed the case if you are a resident or citizen from a non agressive jurisdiction. If you have ties with the EU or US it becomes much more complex and those countries agressively go after someone if they believe that person owns them tax (and they believe that rapidly)...
  20. M

    UAE clarification of Freezone Qualifying Income

    This is something I had posted before but marked as nonsense. Just as everywhere, substance means real substance, not just some fake office and nominees. This setup may work in Dubai (for now) but the veil will be pierced by any other jurisdiction if you have related companies or reside...

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