Could this structure work considering possible residence locations and other factors?

[crsp]

Proposed structure.

IBC with corp' nominee director. Biz activity is income from staking crypto - some active management required. I'm employed (if necessary) somehow as an independent consultant/advisor so can dictate biz operations without triggering PE clauses.

Offshore trust with corp' trustee. Trustee is owner/shareholder of IBC. Trust receives dividends from IBC and set up so dividends can pass through directly to beneficiaries. Wife and myself are beneficiaries. I'm settlor of trust.

I'm a UK national but been resident in Thailand for 10 years. Wife is a Thai national. We are soon need to relocate and might end up living in either Cyprus, UK or Thailand. If live in Cyprus or Thailand, I'd be only beneficiary to receive from trust, if live in UK then wife would be - and she'd claim remittance basis tax there. Offshore bank accounts would be used by both of us. No tax on dividends in Cyprus for non-dom residents and Thailand tax is territorial.

Could this be done and work in the 3 potential tax jurisdictions where we might be tax residents? Where best to have the trust and IBC? Better to use a foundation? UBO, CFC, P.E. issues anywhere? Problems? Suggestions? Comments? Obviously both the trust and IBC will need bank/EMI accounts”¦

Thanks.

Last edited: Oct 8, 2020

 

[blizz]

Move to Cyprus, find a good account here https://www.offshorecorptalk.com/resources/categories/company-formation-provider.2/ ask him to help you setup a good tax(free) structure in Cyprus. There are a few good accountants there that know what they are doing.

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[CaptK]

I think this is more complicated than it needs to be. You can set up an SPV (UAE) that holds the assets in your wife's name and make yourself the CFO of the company with contract and salary.

The asset's were in place before you moved. So I would suggest you calculate how much you need to set up in your new country if possible. Use that to move across with. If the UK is your preferred choice she gets the first years dividends payment tax free (remittance basis) and then you collect a salary taxable.

Double check with an accountant but that's the line to look at.

 

[crsp]

Thanks for replies. This idea has been scrapped now - nevermind bank/EMI reporting and PE issues, problem with trying to do such things now is covid travel restrictions and quarantine...