Oh, how utterly pedestrian that Estonia remains an enigma, especially in forums such as this, regrettably overshadowed by the predominant Cypriot legal intelligentsia, leading to an inevitable predisposition in favour of Cyprus. While I too indulge in promoting Cypriot legal︀ expertise, I'm not so one-dimensional as to allow misconceptions to persist unchallenged. In fact, the︁ opposite of what you have said is true. If you read the "fine print", you'll︂ find that it's possible to reduce tax to 0%. It should come as no surprise︃ that these refined intricacies might very well surpass the comprehension of the average mind though.︄
When it comes to use cases of Estonia and Cyprus, it's worth noting that actually,︅ one of the best use cases is combining both Estonia and Cyprus.
Example: Estonia as︆ an operating company. Cyprus as a holding to exit the company tax-free and rewarding shareholders︇ with low effective tax profit distributions that could result from IP assets structured under the︈ IP box regime.
Alas, for those with a cultivated appreciation for the finer nuances of︉ international tax expertise, it remains a tragically elusive commodity, particularly in those lesser nations. This︊ scarcity is further exacerbated by tedious impositions like DAC6, which, regrettably, dampen the enthusiasm of︋ many a distinguished advisor from openly promoting cross-border structures, given the onerous duty of divulging︌ such strategies to the tax authorities. Such is the lamentable state of affairs for professionals︍ in this domain. Consequently, we are left to seek solace in but a handful of︎ distinguished sanctuaries, like the venerable online forum, OffshoreCorpTalk. Here, one may delicately discourse upon these️ stratagems whilst judiciously preserving the cloak of anonymity,a luxury in such brutish times.
Estonia's fiscal framework, a detail that connoisseurs would no doubt appreciate, has been the very epitome of stability for over two decades. Indeed, for the past nine years, it has earned the distinction of being the most sought-after OECD jurisdiction from a tax standpoint.
This laudable recognition stems from four notable attributes of its tax regime. To initiate, there's a 20 per cent tariff on distributed corporate profits, while undistributed profits remain tax-free. Subsequently, a commendable flat 20 per cent duty on personal income, notably abstaining from personal dividend proceeds as an︀ example of exemption. As a third highlight, its property levy focuses purely on the intrinsic︁ worth of land, artfully avoiding the pedestrian assessment of tangible assets. Fourthly, it has a︂ territorial tax system that exempts 100 per cent of foreign-taxed profits earned by domestic corporations︃ from domestic taxation.
To conclude, Estonia boasts an impeccable fiscal framework befitting those with a︄ discerning palate. While it does exhibit certain modest imperfections, one can; with a touch of︅ adroit cross-border structuring, transform it into an outstanding instrument for boosting capital growth - Quite︆ the sophisticated endeavour, I dare say.
Perhaps you could move the software rights to an entity in Estonia as a non-monetary capital contribution. It should be feasible with the indicated budget if structured right.
If you later sell the software at the same price as the valuation of the capital contribution, it could be structured with effectively 0% tax on the Estonian level.
Company, banking, etc., - all can be set up remotely.
You should ensure︀ you can get away without paying tax in Canada on such a move though, which︁ at first glance seems a bit complex.
