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    Jurisdiction with a tax treaty with Portugal, but dividends exempt from taxation

    Issue I see, is that the UK company (regardless of the ownership) could be considered as PE in Portugal. So in this respect that CFC rules above (that I do not entirely understand) are quite important
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    Jurisdiction with a tax treaty with Portugal, but dividends exempt from taxation

    So if the UK tax company pay directly to NHR in Portugal, the dividend will not be taxed (not by UK, nor by Portugal) UK, with 19% (soon 24%) CIT would not ce subject to the Portuguese CFC rules, from what you write above. Would it mean that a UK limited controlled from Portugal that pays...
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    Company in Bulgaria for software devs

    I totally agree that Cyprus is a great option comparing to _higher_ tax jurisdiction. However, I do think that the OP has an easy and safe option has a 10+4.5% tax base, so, personally I would take that. If he wants to take a risk (and it is a risk that a non dom status in Cyrpus doesn't...
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    Company in Bulgaria for software devs

    I would not bother. Not only you need proper planning and structuring, that is not cheap, but you will always possibly incur the risk of being resident _also_ somewhere else, that given that the residency rules in Cyrpus are very light, may easily win a tie break. And this means also your...
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    Company in Bulgaria for software devs

    Looking at your situation, you have two (and half) options 1) Pay corporate tax in Bulgaria, and consider yourself with a center of interest in one country (Bulgaria?) and pay dividend tax there (10%+5%) 2) Pay corporate tax in Bulgaria, and do not consider you tax resident anywhere (10%+0%)...
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    How helpful is consulting one of Big4 accounting firms for tax optimisation strategies?

    I was in touch with them with relatively and general advise about dual countries residency, corp taxation, and PE, and they asked me around 19k. I though was way out of the park (by a factor of 12) for the type of advice asked, that probably was worth 1/2 days of work.
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    Recommendation for nominee directors in UK

    Does anyone has any experience with this, I found many service online but could use a recommendation of anybody having done this already? :)
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    Recommendation for nominee directors in UK

    My company is a software / consulting provider. Only one client based outside uk
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    Recommendation for nominee directors in UK

    Can somebody recommend a service for local UK resident nominee director? I am going abroad but I would like to keep substance in the country.
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    Georgia - Low cost setup with individual entrepreneur scheme

    Hi Orange Kangaroo I have a Limited Company in uk, that does software development. It needs to stay as it is, as it has a number of contract with existing customer. I was thinking to create a Georgian 5% software company and become tax resident in Georgia - Limited company in UK invoicing...
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    Georgia - Low cost setup with individual entrepreneur scheme

    Thank you Here is an interesting article about eligibility of 1% small business rule: https://forbes.ge/blogs/1-personal-income-tax-applicable-in-georgia-what-to-know-and-consider/ and about the residency rules...
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    Georgia - Low cost setup with individual entrepreneur scheme

    No, that seems not correct, there is no withholding tax on dividend regardless of the country you are , and regardless if you have DTT with UK. There is witholding on Interest & Royalties, but not on dividends.: Dividends There is no requirement to deduct WHT from dividends. Therefore...
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    Georgia - Low cost setup with individual entrepreneur scheme

    Thank you LoveMyLife, that was useful insight Although both OrangeKangaroo and myself are looking at moving our residence in Georgia, one thing is not clear about your comment: The corportae income tax in UK is 19% and there is no dividend withholding (you pay tax on dividend where you are...
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    CFC rules as a non-dom resident in cyprus

    I had a similar question few weeks ago (UK limited, but the point is exactly yours, no tax advantage, just convenience). The summary was that you need to establish substance for your company in the incorporation country otherwise the company will follow you. This seems not to be enforced...
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    Georgia - Low cost setup with individual entrepreneur scheme

    My UK company is established for many years and I cannot easily change it, as there are many the contract signed with customers. If I woudl start today, and knowing I would not be based in UK anymore, I would have done different choices, but it is, what it is now. Anyway, thank you for you...
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    Georgia - Low cost setup with individual entrepreneur scheme

    Well, really you can only invoice following the principle of arm's length, what you are proposing is going to send you straight to jail, so yes, you are going to be able to shift some profit to your Georgian entity, but you are going always to have a profit from UK company that still you would...
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    Irish company while resident in Italy

    >You write "that I don't really know": you mean the level of taxation by the Irish taxman on dividends from US, UK, AU, etc. stocks that my Irish company would have? correct > So the Italian taxman wouldn't see the source of incomes in the Irish company, right? They would just see the...
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    Irish company while resident in Italy

    I now re-read and I see your question is about dividend tax paid by the company on dividends of the stocks My answer was about dividend paid to you from the Irish company The Irish company will pay tax based uniquely on Irish corporate tax rules, that I don't really know, but probably are easy...
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    Irish company while resident in Italy

    >1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. Means you just pay 26% in Italy
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    Irish company while resident in Italy

    Assuming you have substance in Ireland, as you seems to have, my comment is not anymore relevant. In the setup you describe the tax on dividend paid to you are subject (and this is a very generic concept not only applicable to the countries we are describing) - if any, to dividend withholding...

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