Not sure why would you want a︀ Cypriot holding company. As a domiciled entity it'll be liable for taxation there, as far︁ as I understand. So it'd erase all the benefit of not having to pay the︂ 5% on dividends from the Romanian company.
Imo it's better to just employ someone for︃ a minimum wage in Romania to create an economic substance there, and hold it directly,︄ receive dividends to an offshore account while living in Cyprus. You'll pay 0% or 5%︅ on those dividends, 1% on the company revenue, and that's it. Just show up in︆ Cyprus, show them your company bank statements or your personal bank statements and obtain residency.︇
CFC rules and PE / POEM rules are two different things. A company can have︈ a local PE and be liable for taxation even without being considered a CFC by︉ some exclusion.
If the Estonian company has no economic substance in Estonia, and it's managed︊ from Malta, it'll be liable for taxation in Malta to the extend to which its︋ profit is attributable to the PE in Malta, which is 100% in that case, because︌ the income is seen as arising from Malta, a place where the business is in︍ fact being conducted.
https://cfr.gov.mt/en/inlandrevenue... for Individuals under the Income Tax Act.pdf
The non-dom regime and︎ CFC exclusion is only good if no work is being done in Malta, and the️ company is only owned by a non-domiciled resident of Malta.
Imo it's better to just employ someone for︃ a minimum wage in Romania to create an economic substance there, and hold it directly,︄ receive dividends to an offshore account while living in Cyprus. You'll pay 0% or 5%︅ on those dividends, 1% on the company revenue, and that's it. Just show up in︆ Cyprus, show them your company bank statements or your personal bank statements and obtain residency.︇
CFC rules and PE / POEM rules are two different things. A company can have︈ a local PE and be liable for taxation even without being considered a CFC by︉ some exclusion.
If the Estonian company has no economic substance in Estonia, and it's managed︊ from Malta, it'll be liable for taxation in Malta to the extend to which its︋ profit is attributable to the PE in Malta, which is 100% in that case, because︌ the income is seen as arising from Malta, a place where the business is in︍ fact being conducted.
https://cfr.gov.mt/en/inlandrevenue... for Individuals under the Income Tax Act.pdf
The non-dom regime and︎ CFC exclusion is only good if no work is being done in Malta, and the️ company is only owned by a non-domiciled resident of Malta.
