Correct setup for cryptotrader?

[Fred]

From Dubai Bank point of view you are Bulgarian Citizen (if even - it's not︀ mentioned from your side) with Residence in Dubai, UAE.

They don't care and not responsible︁ for anything outside the UAE.

Assuming you are not even Bulgarian Citizen - it's impossible︂ for Dubai Banks to see any link to Bulgaria Residence.

 

[ADROCK123]

your dubai company turns into a bulgarian company because of cfc rules

 

[algotrader]

No, one of the big advantages in Bulgaria is that " CFC rules‌ do not apply to taxes of individuals. If the company is controlled by a physical‍ person who is a Bulgarian tax resident, the Bulgarian Controlled Foreign Company rules do not⁠ matter.". CFC rules are currently only applied if there's a parent holding company in Bulgaria⁤ owning a subsidiary abroad. And it depends on how much substance there's abroad.

https://www.newbalkanslawoffice.com/cfc-rules-in-bulgaria/
Of course, it might change in the future.

 

[Don]

CFC might not⁢ apply, but PE and PoEM might result in the same (so the risk depends on︀ the structure & activities)

 

[Houdini]

can you please spell it out for‌ a nowise like me?

 

[Don]

Permanent establishment (PE)​

PEs of foreign tax residents (e.g. branches) are treated as separate‍ entities similar to Bulgarian residents for tax and accounting purposes.

The definition of a PE⁠ in the Bulgarian legislation follows, in general, the Organisation for Economic Co-operation and Development (OECD)⁤ model; however, it covers a broader scope of activities leading to a tax presence in⁣ Bulgaria. A PE is generally defined as a fixed place (own, rented, or otherwise used)⁢ through which a foreign entity partly or wholly carries out business activities in the country.︀

Place Of Effective Management (PoEM)​

POEM refers to a place where the key management and︁ commercial decisions necessary for conducting a company's business activities are made. Since the residential status︂ of any entity is to be determined every year, POEM is also required to be︃ determined yearly.
Place of Effective Management is an internationally acceptable test to determine, whether a︄ company incorporated in a foreign jurisdiction, is a tax resident of another country

 

[myhand]

Most traders are located in Bitcoin Valley Zug in Switzerland, have you looked in that‌ direction already?

 

[FixieHartmann]

Can anyone report how the daily life in‍ Zug is? I'd imagine it to be quite calm and boring?

 

[Fred]

Boring is what clients told us‍ after living there.

Age of them was between 25-35.

 

[algotrader]

It all depends all on your lifestyle preferences. For some‍ it might also be considered boring to spend most of the year indoor in an⁠ autocratic sharia law desert country with the air conditioner running all the time.
Zug is⁤ located in the middle of the alps with lots of lakes nearby, so it can⁣ be interesting for outdoor/skiing/mountaineering/hiking/water sports enthousiasts. There's indeed no nightlife but you can always drive⁢ to Zürich (a metropolitain area with 1 Mln inhabitants) which is less than 1h away.︀
But the main problem I see with Zug is that it has some of the︁ highest living costs in the world with the most expensive real estate and taxes aren't︂ that low when you consider not just corporate taxes but also income and wealth taxes.︃ Dividends are taxed as income in Switzerland (with some discount). Capital gains are only tax︄ free for private passive investors with long holding periods, not for traders and corporations (there's︅ a detailed set of rules applicable for each canton).