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I think a UK international tax lawyer would know these rules. If you're willing to move then there are all kinds of options. From a cursory reading of the law, one option could be to use the finance company exemptions that are designed to lure international companies to have their headquarters...

The law says "non-UK resident company", and that means any company that is not a "UK resident company". It includes the Cyprus corp. https://www.legislation.gov.uk/ukpga/2010/8/part/9A see 371AA(3) Actually with 100k gbp/month you can create enough substance and also since Cyprus is within EU...

As Martin says, it's best to contact a competent tax lawyer in Malta, but here's my armchair analysis: So this is what the regulation says: Article 7 1. The Member State of a taxpayer shall treat an entity, or a permanent establishment of which the profits are not subject to tax or are exempt...

I don't see how this avoids the CFC rules in UK as you control >25% of the companies involved. In which case you're paying for a lot of puff and smoke.

The CFC rules of which jurisdiction?

what are the impossible documents?

On the same page: Global Trade Solutions AG a licensed financial institution in Switzerland Today Panama based Crypto Capital a Financial Institution is connecting the Fiat and Crypto world together allowing Crypto Currencies to interact with fiat currencies in a similar seamless way. So what...

Where do you find the 10% threshold in the US? You migth be confusing the CFC rules with the UBO rules. Btw, the US is "25% or more" not "more than 25%". Big difference!

MLD4 (used in EU) actually says "more than 25%", so you only need 3 people. OTOH, there will always be someone, and this someone will now be the director(s). A shareholding of 25 % plus one share or an ownership interest of more than 25 % in the customer held by a natural person shall be an...

What's the point of being non-resident in Georgia when Georgia has territorial taxation?

I can probably help you.

I don't know how those banks will react, but there's significant crypto mining activity in Scandinavia, so the banks should already be doing business with these kinds of companies.

Northern Europe has relatively clean mining activity as they have surplus hydro energy. Do you want to pay taxes?

Whoever provides this service needs to deal with the fact that bitcoin is non-reversible while credit cards have chargebacks. Whether that's through higher fees, slower settlement or collateral I don't know.

? Isn't this an accounting question?

Is this PDF available somewhere? The link seems to be dead.

No need to make fake sales - this is just an increase in paid in capital. You can emit more shares to yourself, but you don't have to. Some examples to make this more clear.

From your description it seems like you need to fix both your e-commerce setup and your asset protection setup. It's not clear why your assets are a problem - can't you just hold them in some offshore company with nominees? For the e-commerce part, can you shard your business? I.e. can you...

At a minimum, big companies package up most of what they do as intellectual property which is taxed at 4.5% in Hungary. But that's just the start. Most of them pay 0.X% where X is a very small number.

Also the CIT isn't bad in Hungary! That said, one option is to make use of some anti-CFC setup. You share ownership of an offshore / low-tax entity with others so you get less than 50% ownership. You lose control, you lose ownership. The trick is to use contract theory and game theory to keep...