Hi all
Could you please tip me on the best way of setting up an investment vehicle to pay myself dividends tax-free under Portuguese NHR I already have?
Understand everyone is sick with NHR already, at the same time I have done my homework well and spoken to a few Portugal consultants.
No two similar opinions, or guarantees and some consultants here are just tourist trap dummies 🙂
Happy to pay for consultation on the solid scheme if with a few references to EU/Portuguese tax code or rulings or court practice
Musts
- investment company / trust / LLC / Ltd, etc for purchasing and renting︀ out property in the EU and investing in stocks, futures and other derivatives (Portugal CGT︁ is 14%-28%...)
- occasional consulting service contracts may be done to EU companies but the︂ last priority
- pay all profit to me as dividends so it is legally 0%︃ under Portuguese NHR (As far as I understand director's salary would be taxed at 20%︄ + social security under PT NHR)
- maintenance fees under $5000e yearly for lawyers, virtual︅ office-secretary-directors, etc
- not banana republic to be able to get bank accounts and buy︆ property in the EU
- no or under 20% corporate tax, otherwise to be able︇ to use a bank card to pay director's (mine) living costs - accommodation, car, some︈ travel and meals, attending training, software, subscription. May reposition to lifestyle blogging if needed
- as simple accountancy and reporting as possible (200-500K euros maximum in holdings)
- EU member︉ as simplifies CFC requirements drastically from my understanding, if not then DTA and not on︊ blacklist with Portugal
Good to have
- crypto-trading and banking friendly - to be able︋ to legalize profits and take them out super fast if needed
- reporting in English︌ and not the local language
- anonymity or asset protection from courts but not that︍ necessary
Options that looked appealing for me so far, could you correct if missed anything?︎
- US LLC
pro - no taxation for non-residents, English, low maintenance and good reputation️
con - SEC and IRS are quite harsh, another side of the planet from EU, some financial instrument limitations
- UK LLP
pro - no taxation for non-residents, English, low maintenance and good reputation, good DTA with Portugal and almost any other country
con - income is distributed to partners and cannot be withheld - would NHR consider it "dividends" or "salary" or "foreign income that may be taxed (but not taxed)"? At which tax rate?
- Estonia
pro - all digital and efficient, under 2000e maintenance? good reputation, EU member
con - 20% div withhold tax on the distribution, but distribution may be delayed︀ and then some profits drained through salaries
- Cyprus
pro - 1.5% div tax and︁ no tax on stock trading for non-residents?
con - non-English, high bureaucracy and ~5000e maintenance︂ costs, "grey" reputation, need to hold meetings on Cyprus
- Malta
pro - 5% tax︃ after rebate
con - high bureaucracy and ~5000e maintenance costs, "grey" reputation
- Romania and︄ Bulgaria - EU, barely any taxes but "banana republics" which may be a problem long︅ term and with setting up bank accounts 🙂
Could you please tip me on the best way of setting up an investment vehicle to pay myself dividends tax-free under Portuguese NHR I already have?
Understand everyone is sick with NHR already, at the same time I have done my homework well and spoken to a few Portugal consultants.
No two similar opinions, or guarantees and some consultants here are just tourist trap dummies 🙂
Happy to pay for consultation on the solid scheme if with a few references to EU/Portuguese tax code or rulings or court practice
Musts
- investment company / trust / LLC / Ltd, etc for purchasing and renting︀ out property in the EU and investing in stocks, futures and other derivatives (Portugal CGT︁ is 14%-28%...)
- occasional consulting service contracts may be done to EU companies but the︂ last priority
- pay all profit to me as dividends so it is legally 0%︃ under Portuguese NHR (As far as I understand director's salary would be taxed at 20%︄ + social security under PT NHR)
- maintenance fees under $5000e yearly for lawyers, virtual︅ office-secretary-directors, etc
- not banana republic to be able to get bank accounts and buy︆ property in the EU
- no or under 20% corporate tax, otherwise to be able︇ to use a bank card to pay director's (mine) living costs - accommodation, car, some︈ travel and meals, attending training, software, subscription. May reposition to lifestyle blogging if needed
- as simple accountancy and reporting as possible (200-500K euros maximum in holdings)
- EU member︉ as simplifies CFC requirements drastically from my understanding, if not then DTA and not on︊ blacklist with Portugal
Good to have
- crypto-trading and banking friendly - to be able︋ to legalize profits and take them out super fast if needed
- reporting in English︌ and not the local language
- anonymity or asset protection from courts but not that︍ necessary
Options that looked appealing for me so far, could you correct if missed anything?︎
- US LLC
pro - no taxation for non-residents, English, low maintenance and good reputation️
con - SEC and IRS are quite harsh, another side of the planet from EU, some financial instrument limitations
- UK LLP
pro - no taxation for non-residents, English, low maintenance and good reputation, good DTA with Portugal and almost any other country
con - income is distributed to partners and cannot be withheld - would NHR consider it "dividends" or "salary" or "foreign income that may be taxed (but not taxed)"? At which tax rate?
- Estonia
pro - all digital and efficient, under 2000e maintenance? good reputation, EU member
con - 20% div withhold tax on the distribution, but distribution may be delayed︀ and then some profits drained through salaries
- Cyprus
pro - 1.5% div tax and︁ no tax on stock trading for non-residents?
con - non-English, high bureaucracy and ~5000e maintenance︂ costs, "grey" reputation, need to hold meetings on Cyprus
- Malta
pro - 5% tax︃ after rebate
con - high bureaucracy and ~5000e maintenance costs, "grey" reputation
- Romania and︄ Bulgaria - EU, barely any taxes but "banana republics" which may be a problem long︅ term and with setting up bank accounts 🙂
