Ecommerce business Malta, NHR Portugal

[fshore]

We have been doing this in Germany (with a UK company) without triggering︇ any kind of profits tax in Germany. Also you could use the Malta Germany tax︈ treaty which says that a warehouse doesn't create a permanent establishment.
I guess your problem︉ was related to the fact that you were German and trying to get out.

Anyway, germany was just an example. OP could fulfill from Ireland or another place.

 

[Enrique123]

Hi @Fred - thought id post a short update on a recent line of thought‌ for our structure:

We are juggling the idea of maintaining all Spain operations under the‍ Spain company, but create a holding company in Malta (which would be the 100% owner⁠ of the Spanish company).

This would I think benefit in two ways:

1. We can⁤ draft a royalty agreement between SpainCo and MaltaCo for the use of the brand (and⁣ hence pay no dividend tax if the owners are based in Portugal under NHR)

2. Continue paying corporate taxes in Spain under the 25% corporate tax rate, but transfer after-tax⁢ profit to MaltaCo

This solution seems to avoid us moving business operations to Malta (thereby︀ avoiding the issues you highlighted earlier).

Interested to know your thoughts on the same (whether︁ the above is indeed true, and whether you see any considerable risks).

Thanks as always︂

Amrit

 

[Enrique123]

Hi @Vince

Apologies - I somehow missed your comment and just read it︌ today when I logged into my account.

We've pretty much given up on the Portugal/Malta︍ option, and are just considering Malta (as you suggest).

Interested in knowing a little bit︎ more about how you decide what % of profits to pay in the US and️ what % to send to Malta. Are you using some sort of royalty agreement? What‌ sort of risks are invovled and would you have any advice for us in this‍ area?

Thanks in advance!

Enrique