Cyprus and Malta non-dom status with an Estonian LLC?
- Thread starter sriracha
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I was referring to individual tax residency or staying non-tax resident. Permanent establishment risk (or 'PE risk'), is the risk that the presence of an enterprise in a foreign country has inadvertently created a 'permanent establishment' in that country. Meaning the enterprise may inadvertently be liable for corporate income tax and any attendant penalties and interest charges.
theres a new shell company act which will come into force this year or from 1st jan next year too, these complex structures will be scrutinized
Let me get this straight. If I create a Estonian company and rent an apartment there︆ all year round I become a tax resident? They really don't care about the 183︇ days? Can I get a tax certificate after the first year that will be accepted︈ by other countries? Has anyone tried this?
What do you mean?︎ That even if Estonia considers me a tax resident as an individual, working online from️ another country could trigger PE for the company? Even if I spend less than 183 days in that country? I'm talking about having a company in Estonia as a one man operation by the way. What about CFC rules?
Could you please elaborate? What kind of structures are you referring to?
What do you mean?︎ That even if Estonia considers me a tax resident as an individual, working online from️ another country could trigger PE for the company? Even if I spend less than 183 days in that country? I'm talking about having a company in Estonia as a one man operation by the way. What about CFC rules?
Could you please elaborate? What kind of structures are you referring to?
Yes, personal tax certificate you can get immediately. No need for company (tax residency certificate you can get for company too - it just takes 1 minute whenever you need it). You can visit Estonia one time for one day and keep the personal tax residency next︀ 10 years without ever visiting again, as you can do everything remotely anyway with digital︁ services including obtaining such certificates.
Is that really true? Do they get different forms for 183-day and 60-day certificates? Then it takes all the meaning out of this non dom regime
If you have tax risk exposure in some other country you shall always first consider the treaties, and only in case no treaty exist you shall refer to the domestic legislation.
There is no reference to 60-days tax residency in the treaty residence tests. From treaty perspective what can help you actually is maintaining a home in Cyprus year-round and other substance.
The tax residency certificate should clearly state the basis of the underlying︀ double tax treaty.
There is no reference to 60-days tax residency in the treaty residence tests. From treaty perspective what can help you actually is maintaining a home in Cyprus year-round and other substance.
The tax residency certificate should clearly state the basis of the underlying︀ double tax treaty.
It's always begins with a residency certificate. If one couldn't provide it, no matter how long he lives in Cyprus, no other country︀ will apply a treaty. Therefore, if Cyprus does not provide a proper certificate, its attractiveness︁ is significantly reduced.
CyprusLaw can you send me a PM too. I have similar question to ask you.
CyprusLawyer101, can you PM me. I have a similar question to ask you.
CyprusLawyer101, can you PM me. I have a similar question to ask you.
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