Company with substance - 0% tax

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sergeylim88

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Dec 1, 2018
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guys where would you setup a company with substance (ex. employees, director, secretary) that would allow you 0% tax?
consider that the beneficial owner is resident in 0% tax country, so no issues with PE/CFC.

does anyone know of Seychelles IBC company is allowed to have employees and actual office in Seychelles?
 
In the same country where the UBO is resident since⁠ it's a 0% tax country?
 
(U)BO is in a country where he can receive dividends tax free, but he can‌ not manage the company from there (and companies there pay taxes), that's why the need‍ for substance
 
The usual list that are truly zero tax corporate and personal: Monaco, the zero tax‌ Caribbean islands, and Pacific islands. Bahrain but probably not for long. Sadly not the UAE‍ anymore.

Or relocate to a territorial country, but then the business must be elsewhere.
 
monaco does have a tax for companies registered there that have income from abroad (above‌ certain threshold)
 
The question was about suggesting a place for UBO relocation

In any case managing a‌ US LLC from Monaco could work without the need of director, office and employees since‍ AFAIK US LLC is tax transparent in french eyes and Monaco doesn't tax personal income⁠ so it's tax free.

If UBO needs help he could hire a contractor or hire⁤ through and EOR like remote.com
 
Substance comes down to employing subjects and office space.

For example, a BVI company in‌ the say Infrastructure - Investment Field.

Min Salary in BVI is 6$ per hour.

You have someone work a few hours a day watching interviews from the day or the‍ day before, taking notes (deriving important periods - as set) 300$ a month (1.5hrs a⁠ day).

You have someone doing research on projects/companies in the field and compiling notes 400$⁤ a month.

Get the drift?

Then you have office space (rent local of the local⁣ employed, pay the utilities for the office space for them to work).

Get the drift?⁢

Pay taxes - if any taxes (say BVI) for their payroll - pay it 10%︀ ++

Get the drift???

GDP - Corporate Tax...

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Now most businesses are automated like︁ web based, so have all your bills go there so your business is operating from︂ there (office space rented) calls dealt with there (filtering) etc...

Seychelles has reportedly become a pain in the︇ arse since 2020... you have to employ local directors also there now i think.
 
thank you, i understand the concept of substance
my main question is which countries will‌ allow having local director and employees while keeping the 0% tax rate.
does anyone know‍ if seychelles will allow this(for income coming outside of seychelles)?
 
Nothing beats UAE on all levels even with︅ 9% cit which is not confirmed yet.
 
I remember deep diving into the Kazakhstan free zone, to avoid being taxed at 20%,‌ on top of having to fit some activity types and having local substance, there was‍ also restriction on what you can outsource outside of the country. So it seemed quite⁠ strict on paper about "you better f****** do it from Kazakhstan". I don't know how⁤ it goes in practice.
 
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