Best approach for holding

[oa13]

Hello All,

Let me expose a case and hope you can guide me.

I have company for quite some time in france that generate around 200k profit after corporate tax in France and im fine paying this tax.
All my customers are in France so i have to pay and im not planning to have other customers outside.

I dont have salary , i take only 12k year dividend for which i pay nothing as tax and this amount is enough for me to live for 1 year.

So let say that my corporate bank account has good money now and now i think it is time for me to invest this money and not leave it there sitting doing nothing.

I have plan to move abroad by this year.

As i said my company will stay in France , im planning to keep paying corporate tax there .

My idea is to create a dubai holding company that will own my french company and transfer all the dividend to this holding and then use this money to invest in stock market and real estate in dubai from this company on Dubai.
I plan also to take some dividend for myself from my dubai company.

I pay my corporate tax in france for my french company and i plan to keep paying them , not trying to avoid them

Maybe you will ask why i dont create holding in France and do it ? Well i want to create a country barrier between my operational activities in France from my investment activities in Dubai and want to use my french company only to feed my dubai holding .

Question is if i move to dubai and create this holding :

How can i do it ?
How much will it cost ? Ball park figure
Can the dubai company own real estate ?
Can the dubai company own trading stock account ?
Any risk you see ?

Thanks a lot for your time

 

[W Fish]

I would definately look at having an Estonian co instead of the Dubai one.
Would be easier and cheaper, the company can own real estate and other property, especially easy if in EU, profit not taxed, can trade stocks, crypto, coins, banknotes ....
Risks the same as in France, minus a bit I would say.

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[oa13]

W Fish said:
I would definately look at having an Estonian co instead of the Dubai one.
Would be easier and cheaper, the company can own real estate and other property, especially easy if in EU, profit not taxed, can trade stocks, crypto, coins, banknotes ....
Risks the same as in France, minus a bit I would say.
Click to expand...

Yes i thought about estonia portugal etc..

But for me any EU co = France co = Shi**ty protection if anything goes bad.
EU now is only 1 big jurisdiction and they can take all of your things.

 

[Marzio]

UK holding.

No WHT on dividends, common law, cheap to manage, access to banks, no questions asked by banks when wiring to holding unlike UAE, outside of EU.

 

[Don]

Marzio said:
UK holding.

No WHT on dividends, common law, cheap to manage, access to banks, no questions asked by banks when wiring to holding unlike UAE, outside of EU.
Click to expand...

Could also do UK company treaty resident in UAE. Best of both worlds?

 

[Marzio]

Don said:
Could also do UK company treaty resident in UAE. Best of both worlds?
Click to expand...

Yes, that's another option.

 

[Don]

Looks like a good time to leave.
You can probably avoid French exit tax by staying under the thresholds and leaving before company grows too big.

 

[W Fish]

oa13 said:
Yes i thought about estonia portugal etc..

But for me any EU co = France co = Shi**ty protection if anything goes bad.
EU now is only 1 big jurisdiction and they can take all of your things.
Click to expand...

In case something goes bad, I would not trust any jurisdiction and hold everything not needed for everyday activity in BTC.
I would even argue that i fyou need real estate, then in the current economic situation it is better to rent/lease instead of buying and keep the funds you would use for buying in BTC.

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[oa13]

Don said:
Could also do UK company treaty resident in UAE. Best of both worlds?
Click to expand...

Do you have more to share about this possibility ?

 

[oa13]

W Fish said:
In case something goes bad, I would not trust any jurisdiction and hold everything not needed for everyday activity in BTC.
I would even argue that i fyou need real estate, then in the current economic situation it is better to rent/lease instead of buying and keep the funds you would use for buying in BTC.
Click to expand...

When i say goes bad . I dont mean necessary economic crisis because there are opportunities everywhere.

I m mainly talking about the taxman having control over you

The france taxman can pick up the phone , get a judge to call his collegue in any other UE country and tomorrow he is in control of your things. Your real estate is not yours anymore , your bank account too etc...

I assume it doesnt happen like that with countries outside of EU ??? ( i mean technically it can but it is quite complex for him)

 

[W Fish]

oa13 said:
When i say goes bad . I dont mean necessary economic crisis because there are opportunities everywhere.

I m mainly talking about the taxman having control over you

The france taxman can pick up the phone , get a judge to call his collegue in any other UE country and tomorrow he is in control of your things. Your real estate is not yours anymore , your bank account too etc...

I assume it doesnt happen like that with countries outside of EU ??? ( i mean technically it can but it is quite complex for him)
Click to expand...

No taxman, no judge can get your BTC, exactly that was the pont. 🙂

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[undercover]

W Fish said:
No taxman, no judge can get your BTC, exactly that was the pont. 🙂
Click to expand...

There are plenty of examples of how authorities have seized BTC and many other cryptos

• The US seizure of Silk Road's Bitcoins (2013):
  In October 2013, the FBI shut down the illegal online marketplace Silk Road and seized around 144,000 Bitcoins, worth approximately $33 million at the time.
• Europol's operational efforts against crypto-related crime (2020):
  In 2020, Europol collaborated on seizing significant amounts of cryptocurrencies as part of operations targeting illegal online activities.
• Australia's seizure of Bitcoin in drug cases (2021):
  In 2021, Australian authorities seized Bitcoin and other cryptocurrencies as part of a larger operation against drug smuggling and illegal online activities.

 

[Don]

oa13 said:
Do you have more to share about this possibility ?
Click to expand...

Do you really want to live most of the year in Dubai for real? You mention wanting to move abroad but are you moving to Dubai?
With 12k euros per year, I have doubts you will afford the lifestyle you expect in Dubai.
Only the corporate and residence setup there can cost you more than that.
Also, quite potentially, you are facing exit tax in France. With this in mind, considering EU countries for holding and tax residence could be a better option.

Say you establish a holding and tax residence in Estonia. All dividends can flow through the holding to you tax-free. This setup costs very little, and is less scrutinized by French authorities.

France recently extended the statute of limitations in cases of false foreign domiciliation from three to 10 years. This extension allows the French tax authorities more time to investigate and address cases where individuals falsely claim to reside abroad to avoid French taxes.

 

[W Fish]

undercover said:
There are plenty of examples of how authorities have seized BTC and many other cryptos

• The US seizure of Silk Road's Bitcoins (2013):
  In October 2013, the FBI shut down the illegal online marketplace Silk Road and seized around 144,000 Bitcoins, worth approximately $33 million at the time.
• Europol's operational efforts against crypto-related crime (2020):
  In 2020, Europol collaborated on seizing significant amounts of cryptocurrencies as part of operations targeting illegal online activities.
• Australia's seizure of Bitcoin in drug cases (2021):
  In 2021, Australian authorities seized Bitcoin and other cryptocurrencies as part of a larger operation against drug smuggling and illegal online activities.

Click to expand...

Remember - not your keys => not your Bitcoin. 😉

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[undercover]

W Fish said:
Remember - not your keys => not your Bitcoin. 😉
Click to expand...

So now you're just posting random stuff and copying another user on the forum who used to make the same kind of meaningless posts.

Honestly, that says more about you as a user than anything else, and it's definitely not doing your reputation any favors, if that's what you're aiming for.

 

[W Fish]

undercover said:
So now you're just posting random stuff and copying another user on the forum who used to make the same kind of meaningless posts.

Honestly, that says more about you as a user than anything else, and it's definitely not doing your reputation any favors, if that's what you're aiming for.
Click to expand...

I am really sorry, if this was too complicated for you.
What I was meaning was that in the quoted confiscation cases the owners of confiscated BTC did not hold the private keys for it. If you are not holding the keys, you are trusting somebody else to keep your coins. This makes theft/confiscation possible.


See how much I care about what you thinnk of me as a user or my reputation. 😛

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[oa13]

Don said:
Do you really want to live most of the year in Dubai for real? You mention wanting to move abroad but are you moving to Dubai?
With 12k euros per year, I have doubts you will afford the lifestyle you expect in Dubai.
Only the corporate and residence setup there can cost you more than that.
Also, quite potentially, you are facing exit tax in France. With this in mind, considering EU countries for holding and tax residence could be a better option.

Say you establish a holding and tax residence in Estonia. All dividends can flow through the holding to you tax-free. This setup costs very little, and is less scrutinized by French authorities.

France recently extended the statute of limitations in cases of false foreign domiciliation from three to 10 years. This extension allows the French tax authorities more time to investigate and address cases where individuals falsely claim to reside abroad to avoid French taxes.
Click to expand...

Hello Don,
below are 2 scenario the way i see it
if you validate one or both of the scenarios that it is possible for me to do them, i will start to ask for step that will help me do all the paperwork etc ...

scenario 1
i have company A in france
my personnal tax residence is france
i pay corporate tax in france for company A
i create holding company B in UK as non resident
Company B invests in stocks
Company B pays corporate tax in Uk
i pay tax in france for any dividend i receive from company B

scenario 2
i have company A in france
my personnal tax residence is france
i pay corporate tax in france for company A
i create holding company B in Estonia as non resident
Company B invests in stocks
Company B pays corporate tax in Estonia
i pay tax in france for any dividend i receive from company B

 

[Don]

oa13 said:
Hello Don,
below are 2 scenario the way i see it
if you validate one or both of the scenarios that it is possible for me to do them, i will start to ask for step that will help me do all the paperwork etc ...

scenario 1
i have company A in france
my personnal tax residence is france
i pay corporate tax in france for company A
i create holding company B in UK as non resident
Company B invests in stocks
Company B pays corporate tax in Uk
i pay tax in france for any dividend i receive from company B

scenario 2
i have company A in france
my personnal tax residence is france
i pay corporate tax in france for company A
i create holding company B in Estonia as non resident
Company B invests in stocks
Company B pays corporate tax in Estonia
i pay tax in france for any dividend i receive from company B
Click to expand...

You need to build substance for these structures, else it will not work.

Cyprus is a great jurisdiction in the EU for a holding company.

 

[oa13]

Don said:
You need to build substance for these structures, else it will not work.

Cyprus is a great jurisdiction in the EU for a holding company.
Click to expand...

thanks Don
just fyi company A is up and running

is my scenario below accurate and if the answer is yes , can someone from the website help me set up this

i live in france and i already own company A
i create company B in cyprus (holding company)
i transfert the ownership of company A from myself to company B
company B now possess company A
at the end of the year , company A transfers dividend to company B
company B invests in stock , real estate blablabla
once a year i can receive dividend from company B
i pay dividend tax in france for those dividends

 

[churumbelo]

Marzio said:
UK holding.

No WHT on dividends, common law, cheap to manage, access to banks, no questions asked by banks when wiring to holding unlike UAE, outside of EU.
Click to expand...

Could a UK holding -I guess you might mean an LTD - be used to hold investments such as stocks and ETFs? Like an IBKR account for instance, and have all of those benefits (maybe no capital gains too)? If so, are there any risks or downsides?