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  1. H

    Making a dividend a cost for your offshore company

    It would be a dedicated director working in the interest of the company. Not in my only interest. Also the substance requirements has weakened, it needs to be sufficient to fulfil the company goals. https://www.loyensloeff.com/be/en/n...-escaping-the-claws-of-the-cayman-tax-n19888/If you know...
  2. H

    Making a dividend a cost for your offshore company

    I'm just doing some research on different setups and treaties that would be interesting in Belgium. So I understand the structures when talking to a tax lawyer and suggest some that I find interesting. I've had one trying to sell the same structure over and over again without looking if that's...
  3. H

    Making a dividend a cost for your offshore company

    Low cost of labour with only a 2 hour difference, for customer support, administrative support and personal assistant. Also a location where all outsourcing is tracked and managed. Why do you think it requires more investment? You pay $1000 annual fee for the renewal with some extra costs (+-...
  4. H

    Making a dividend a cost for your offshore company

    I'm only looking in to structures with real substance. The Seychelles CSL company is a resident company with access to treaties and local labour. It's also only a 2 hour time difference.
  5. H

    Making a dividend a cost for your offshore company

    Fair enough, I won't pursue. I was just curious if something like that would be possible or something else. You also have these mismatches in other structures where one country sees a company as resident and the other as non-resident for example.
  6. H

    Making a dividend a cost for your offshore company

    Just curious. Why would you choose Estonia as the holding? I'm a resident of Belgium and Belgium has already quite favourable laws for holding companies so I will probably keep it like that. But because my plan with Estonia seems not a great idea I wont pursue. I'm just looking for another low...
  7. H

    Making a dividend a cost for your offshore company

    An Estonian company is not taxed unless the money in the company is distributed. Let's say a Belgium holding company opens an Estonian company, the Estonian company makes 100K profit a year. When the holding company in Belgium needs money, instead of distributing the money as a dividend that is...
  8. H

    Best subsidiary location with substance for a Belgian company

    Does someone know of some other place with low/no tax with access to cheap labour? I think Romania is still No. 1 atm. But I'm open to suggestions!
  9. H

    DTA Opportunities for Belgian resident

    Can you think of some other countries where I can have no/low tax and access to cheap labour?
  10. H

    Best subsidiary location with substance for a Belgian company

    It would seem weird if I want to invest in a country to setup a customer support and marketing base and I hire a director and employees that I need to trust them with all the money on the bank account. The director is there to help and guide the employees. Not to have free access to 6 or 7 digit...
  11. H

    Creating substance using nominees in tax-free countries

    EDIT: whoops I thought you were replying on my thread. Why would Mauritius be that interesting? I see Belgium has a 5% tax on dividends. That's great however Mauritius does make it difficult to have a story other than tax because there is no real economic reason to be there. Mauritius 100...
  12. H

    Best subsidiary location with substance for a Belgian company

    Wouldn't this be easily solved with putting a max on their spend/withdrawal, so they need my signature if they want to go over a certain amount.
  13. H

    Opportunities for dual citizenship holders

    Interesting, thank you. So it will be 2000 usd + appartment rent arround 15.000?
  14. H

    Best subsidiary location with substance for a Belgian company

    Ok, then I know I'm going into the right direction. It definitely is but in my case it's impossible. Maybe in a few years. It will probably be me in the beginning but I'll just make the director a proxy for my decisions. Meetings can be had on Video conference (Zoom or something more privacy...
  15. H

    Creating substance using nominees in tax-free countries

    I like these experiments. In my case it would be almost impossible to proof I live elsewhere. So I'm stuck on finding a good structure that is tax and cost efficient.
  16. H

    Best subsidiary location with substance for a Belgian company

    Pretty sure you are right. However it would also be a logical way for Belgium to get the money back into the country instead of compounding it offshore.
  17. H

    Best subsidiary location with substance for a Belgian company

    But why would it not be genuine if I have a director and 3 employees doing real actual stuff there for example? It's normal to work in every companies best interest you own. So charging my Belgian company at a little above market rate seems like a normal procedure.
  18. H

    Creating substance using nominees in tax-free countries

    Interesting. However, how would you declare the income coming from the nominee?
  19. H

    Best subsidiary location with substance for a Belgian company

    On the link you send under CFC it says: Under CFC rules I also see: "A Belgian company is taxed on the “non-distributed profits” of a foreign company that is considered a CFC where such profits are arising from “non-genuine arrangements” which have been put in place for the essential purpose...
  20. H

    Best subsidiary location with substance for a Belgian company

    Thank you for your concern. Saving taxes is my first goal, but cheap labour is a logic way for me to actually setup a structure other then tax. I'm not going to pay for employees that are not going to work for me ;) They will provide customer support to our Belgian customers and other services...

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