"A company is resident if its seat or place of effective management is in Slovakia", so even without CFC rule the offshore company may be called upon to pay taxes. In the future, the CFC law may also include individuals. Also an exit tax exists.
€700K - Where incorporate and live as digital nomade
- Thread starter Financelady45
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This rule is not for the UAE setup I mentioned, read the DTT between Slovakia and UAE. However, I never heard of anyone who was called to pay taxes from offshore companies. Many ppl looking for security do a Cyprus non-resident company with an office in Malta. That completely avoid the rule you mentioned. Yes,︀ in the future, the CFC law may also include individuals. But in the future also︁ UAE can impose corporate tax or EU tax harmonization can happen. Considering the political climate︂ in the country, it is very unlikely.
Btw. Your 3% Romania setup will not work︃ for her, because 3% is for non-consultancy income.
Btw. Your 3% Romania setup will not work︃ for her, because 3% is for non-consultancy income.
Friends,
Thanks so much for your (all) inputs, I am so happy. I have sorted my idea in two groups:
OPTION 1 (HOMETOWN LTD)
1. Set up a LTD in my home country and buy a small flat where to put all the asset and residency
2. Have myself as Director and get a salary (It will cost me money as I will have to pay also the social insurance, taxes, etc). AND / OR
3. Hire a family member and use his fiscal benefits for the first 3 year + Buy a nice car and some other relevant expenses
4. Pay LTD Corporate Taxes︀ 26% on the remaining income in my home country :-(
5. Repeat the above model︁ for the upcoming years and keep all future income in the LTD
6. Use the︂ LTD to buy properties
7. Have the LTD to rent all properties
8. Get rental︃ income into the LTD
9. Pay myself a salary (Basically the rental income)
If we︄ consider the following:
€675K NET (After Taxes + Saving)
5.5% Income from Rental=€37K
A: If︅ I keep this income taxable in my home country I will have probably approx €20K︆ at my disposal (after taxes).
B. I will be able to travel and relocate in︇ low costs countries and or countries where offer exception under an amount and live as︈ digital nomade.
--->What do you think about the above schema? What can be the risk?︉
Questions:
1. If I get married OR I have some private circumstance, the LTD assets︊ will be protected, they will be able only to attack me for my income as︋ Director, correct?
2. To calculate my worth and aliments a judge can consider also the︌ assets in my LTD?
OPTION 2 (UAE + EU ENTITY)
1. Set-up a FZE company︍ in the UAE to invoice your clients. No acccouting, 0% CPT
2. Set-up a LLC︎ company in Slovakia just to pay yourself a minimal wage. Gross is 520 eur and️ you will get 420 eur. For the 100 eur the state will take, you get relatively decent healthcare (or at least value for the money) and also right for government provided pension when you reach the certain age, the amount will be symbolic because you pay minimal levies but still you will be a net receiver from public system.
3. Disclose your life documentable life in the country of your current tax residency (rent, bank accounts...).
4. Rent / Buy place in Slovakia. You become a tax resident in Slovakia if you spend 180 days per calendar year in the country OR if you have "center of vital interests" in the country - which you will have bc of job,︀ rent and no economic ties to any other country. If you would consider to live︁ in the country, it is decent option. Cost of living is comparable to Poland/Hungary. If︂ you are tired of huge cities, Bratislava offer some balance. From the capital town it︃ is one hour to Vienna, two hours Budapest by car and Prague is reachable in︄ 4 hours by train. Bratislava region is the 3rd richest region in the EU. Eurozone︅ country. No CFC rules for private individuals. Slovakia is still the fastest growing economy since︆ they joined the EU.
5. Pay yourself a dividend from your UAE company. 0% withholding︇ tax imposed by UAE, 7% tax on dividends under DTT in Slovakia.
6. Invest in︈ the real estate of your choice. The income derived from rent is treated as capital︉ gains, taxed at the rate 19% (you will not pay social levies on this). If︊ you will decide to sell the property (and held the property for at least 2︋ years) you will pay 0% tax. 0% tax rate also applies to sell of shares︌ bought on the regulated market (if you hold them at least 12 months). You can︍ buy stuff up to 15k eur in cash, physical gold worth of 10k per transaction︎ also in cash... sell of physical gold is taxed at the rate of 0%.
Questions:
1. I have heard in Europe that if a UAE company has no substance, it️ will be considered as EU Company and a lot of taxes / penalities will be due.
2. I love the idea to have the income tax frees and pay myself a divident (taxable) but what if the above scenario will be applied (tax elusion)?
3. So the UAE company will be the owner of all properties right?
4. Anyone has applied this schema?
What about IRELAND or SWITZERLAND?
Thanks so much for your (all) inputs, I am so happy. I have sorted my idea in two groups:
OPTION 1 (HOMETOWN LTD)
1. Set up a LTD in my home country and buy a small flat where to put all the asset and residency
2. Have myself as Director and get a salary (It will cost me money as I will have to pay also the social insurance, taxes, etc). AND / OR
3. Hire a family member and use his fiscal benefits for the first 3 year + Buy a nice car and some other relevant expenses
4. Pay LTD Corporate Taxes︀ 26% on the remaining income in my home country :-(
5. Repeat the above model︁ for the upcoming years and keep all future income in the LTD
6. Use the︂ LTD to buy properties
7. Have the LTD to rent all properties
8. Get rental︃ income into the LTD
9. Pay myself a salary (Basically the rental income)
If we︄ consider the following:
€675K NET (After Taxes + Saving)
5.5% Income from Rental=€37K
A: If︅ I keep this income taxable in my home country I will have probably approx €20K︆ at my disposal (after taxes).
B. I will be able to travel and relocate in︇ low costs countries and or countries where offer exception under an amount and live as︈ digital nomade.
--->What do you think about the above schema? What can be the risk?︉
Questions:
1. If I get married OR I have some private circumstance, the LTD assets︊ will be protected, they will be able only to attack me for my income as︋ Director, correct?
2. To calculate my worth and aliments a judge can consider also the︌ assets in my LTD?
OPTION 2 (UAE + EU ENTITY)
1. Set-up a FZE company︍ in the UAE to invoice your clients. No acccouting, 0% CPT
2. Set-up a LLC︎ company in Slovakia just to pay yourself a minimal wage. Gross is 520 eur and️ you will get 420 eur. For the 100 eur the state will take, you get relatively decent healthcare (or at least value for the money) and also right for government provided pension when you reach the certain age, the amount will be symbolic because you pay minimal levies but still you will be a net receiver from public system.
3. Disclose your life documentable life in the country of your current tax residency (rent, bank accounts...).
4. Rent / Buy place in Slovakia. You become a tax resident in Slovakia if you spend 180 days per calendar year in the country OR if you have "center of vital interests" in the country - which you will have bc of job,︀ rent and no economic ties to any other country. If you would consider to live︁ in the country, it is decent option. Cost of living is comparable to Poland/Hungary. If︂ you are tired of huge cities, Bratislava offer some balance. From the capital town it︃ is one hour to Vienna, two hours Budapest by car and Prague is reachable in︄ 4 hours by train. Bratislava region is the 3rd richest region in the EU. Eurozone︅ country. No CFC rules for private individuals. Slovakia is still the fastest growing economy since︆ they joined the EU.
5. Pay yourself a dividend from your UAE company. 0% withholding︇ tax imposed by UAE, 7% tax on dividends under DTT in Slovakia.
6. Invest in︈ the real estate of your choice. The income derived from rent is treated as capital︉ gains, taxed at the rate 19% (you will not pay social levies on this). If︊ you will decide to sell the property (and held the property for at least 2︋ years) you will pay 0% tax. 0% tax rate also applies to sell of shares︌ bought on the regulated market (if you hold them at least 12 months). You can︍ buy stuff up to 15k eur in cash, physical gold worth of 10k per transaction︎ also in cash... sell of physical gold is taxed at the rate of 0%.
Questions:
1. I have heard in Europe that if a UAE company has no substance, it️ will be considered as EU Company and a lot of taxes / penalities will be due.
2. I love the idea to have the income tax frees and pay myself a divident (taxable) but what if the above scenario will be applied (tax elusion)?
3. So the UAE company will be the owner of all properties right?
4. Anyone has applied this schema?
What about IRELAND or SWITZERLAND?
You have received many good suggestions, but I feel you keep tilting towards some falsely-perceived sense of security in countries which are very expensive, while you discard other places based on out-of-date prejudice. Most likely, picking those places you perceive as "safe" will not be safer at all, but to the contrary in many such countries the tax authorities can be extremely predatory. Laws often change, and it is usually to the worse. Consequently, the already high taxes and fees became even higher.
No matter where we look, these "old economies" such as the USA, Switzerland or the UK, they will NOT offer attractive rental︀ yields, low taxes, low crime rates, and so on. There are some faraway countries that︁ try to attract foreigners, such as the UAE, Malaysia, Belize, and so on; however, these︂ places are risky exactly because they are faraway, and you are so dependent upon a︃ network of middlemen who you have to trust. As a result, the fees incurred are︄ often huge, and these are ongoing fees. What do you do for example when you︅ want to liquidate the company? It can be incredibly complicated and expensive.
In my opinion,︆ just like so many other people mentioned, you should probably look at Central Europe. If︇ you want to combine it with a good place to live, relatively cheap cost of︈ living and high crime safety, in addition to decent rental yields, it is a good︉ choice. Another option not so far away would be Georgia. It is really a very︊ attractive option, and almost too good to be true, but it is not (only it︋ is less well-known compared to say Cyprus). Georgia is also not ideal as an offshore︌ jurisdiction, but in your case this is not applicable.
No matter where we look, these "old economies" such as the USA, Switzerland or the UK, they will NOT offer attractive rental︀ yields, low taxes, low crime rates, and so on. There are some faraway countries that︁ try to attract foreigners, such as the UAE, Malaysia, Belize, and so on; however, these︂ places are risky exactly because they are faraway, and you are so dependent upon a︃ network of middlemen who you have to trust. As a result, the fees incurred are︄ often huge, and these are ongoing fees. What do you do for example when you︅ want to liquidate the company? It can be incredibly complicated and expensive.
In my opinion,︆ just like so many other people mentioned, you should probably look at Central Europe. If︇ you want to combine it with a good place to live, relatively cheap cost of︈ living and high crime safety, in addition to decent rental yields, it is a good︉ choice. Another option not so far away would be Georgia. It is really a very︊ attractive option, and almost too good to be true, but it is not (only it︋ is less well-known compared to say Cyprus). Georgia is also not ideal as an offshore︌ jurisdiction, but in your case this is not applicable.
There are many places in Europe where the tax is low and where it is safe to be i.e. Malta, Cyprus, Switzerland, Lichtenstein, Luxembourg! Just pick one and find someone in the country that can help you. Almost any of these countries have service providers that help with relocation!
You are right that all these countries can offer these things, but if you start adding more requirements it is a different situation. For example, the thread starter wants to live off rental income. Would Switzerland be a good choice then? Definitely not. What about cost of living? Will she rent︀ an apartment in for example Luxembourg? The rental income would hardly cover her own rent.︁ Will she buy apartments elsewhere and rent them out? Not a good idea. I say︂ again, for the specific requirements she has, she should look most closely at Central Europe.︃
Yes, I would like︀ to live with rental income and have at least 5% - 5.5% rental income before︁ taxes. One consultant said I have to buy a small property in the country which︂ I want to make the center of my interest so that no issues in future.︃ In Switzerland there are low taxes but high expenses, properties, etc.
Article 4, (3). The company is resident there, where it's place of effective management is. In this example Slovakia. I also haven't heard of such cases in countries which don't have CFC rule, but it isn't a guarantee.
By office you︀ mean just an adress or the hired director with physical office?
Some update on my previous post︅ about Georgia. As I discovered it has a lot of typical 3rd word country problems︆ such as corruption and it's definitely not a good place to live, but it seems︇ these problems don't bother people who use it only as a country to get a︈ residence.
By office you︀ mean just an adress or the hired director with physical office?
Some update on my previous post︅ about Georgia. As I discovered it has a lot of typical 3rd word country problems︆ such as corruption and it's definitely not a good place to live, but it seems︇ these problems don't bother people who use it only as a country to get a︈ residence.
I know ppl in Slovakia with the UAE setup and no︁ problem so far. Tax authorities focus more on VAT. However, I suggested the UAE only︂ bc 0% CPT and 0% WHT, people in Slovakia do also a Cyprus non-resident company︃ without any problem. But the setup with effective place of management in Malta is legally︄ bulletproof. You need a director from Malta and a physical address (which cost more than︅ UAE setup). When a beneficial owner need to pay himself dividends from such company, he︆ just appoint a Cyprus director to access DTT.
Another option, when she will make herself︇ a tax resident of Slovakia is:
1. Simply setup Seychelles/Belize (ppl here will advise which︈ is easier and better). Invoice clients through this company. Tax authorities will have no chance︉ to get any information even if they will want to (and they will not) bc︊ of no DTT and no exchange of informations. You do not have to use nominee︋ services bc of no CFC.
2. Seychelles company will incorporate in Slovakia. Through this company︌ you can buy real-estate in Slovakia. Seychelles company will own 90% and you as a︍ private individual will own 10%.
3. You will pay corporate income tax from rent income︎ and the dividend tax you will pay yourself as a director (you need to own️ some shared capital as a private individual, bc dividend would be otherwise treated as ordinary income 19%).
So, you will invest 100% of your consulting income (no tax loses).
Lets say you will make 30k eur / year from rent.
- you will pay yourself a minimal wage 520 eur x 12 = 6240 eur from this you will get 5040 eur to your private bank account (rest is healthcare and social levies). This will be an expense of the company.
- you can also buy a car, do some travelling as company expenses to lower your tax base etc.
- buy of the real estate is also tax expense, but every year you can claim only 1/20 of the︀ value of the property when you bought it. You can do this for 20 years.︁
- so if you buy 3 apartments each worth of 200k... you can claim tax︂ expenses 30k every year (for 20 years)
- your tax base will be -6240 eur︃
- after paying CPT (which is now ridiculously high 21%, but will get lower) which︄ will be in your case 0 eur (for at least 20 years) and then 7%︅ dividend tax (which is promised to be abolished again) you will left with 22096 eur.︆
From the whole 30k you should get around 27136 eur to your private bank account︇ (rest will be taxes and social levies). So the effective tax rate will be around︈ 9,54%.
PROS
- You will invest the whole sum (without the 7% loss on dividends︉ from UAE)
- Assets (or 90% at least) protected from marriage etc., bc owned by︊ Seychelles company
- Legally is this setup slightly better than with the UAE
CONS
- If you will decide to sell the property, you will have to pay CPT, as︋ a private individual there is no tax
- If you rent as a private individual︌ you pay 19% tax, as a company you have to pay CPT + dividend tax︍ (which you can minimize through tax expenses)
- When you will sell the property you︎ will have to sell it with VAT + 20%.
- Soon or later will the️ EU push countries like Slovakia adapt some standardized CFC rules (you will have to appoint nominees then or better in the meantime work on getting the slovak company under your full control).
Another option, when she will make herself︇ a tax resident of Slovakia is:
1. Simply setup Seychelles/Belize (ppl here will advise which︈ is easier and better). Invoice clients through this company. Tax authorities will have no chance︉ to get any information even if they will want to (and they will not) bc︊ of no DTT and no exchange of informations. You do not have to use nominee︋ services bc of no CFC.
2. Seychelles company will incorporate in Slovakia. Through this company︌ you can buy real-estate in Slovakia. Seychelles company will own 90% and you as a︍ private individual will own 10%.
3. You will pay corporate income tax from rent income︎ and the dividend tax you will pay yourself as a director (you need to own️ some shared capital as a private individual, bc dividend would be otherwise treated as ordinary income 19%).
So, you will invest 100% of your consulting income (no tax loses).
Lets say you will make 30k eur / year from rent.
- you will pay yourself a minimal wage 520 eur x 12 = 6240 eur from this you will get 5040 eur to your private bank account (rest is healthcare and social levies). This will be an expense of the company.
- you can also buy a car, do some travelling as company expenses to lower your tax base etc.
- buy of the real estate is also tax expense, but every year you can claim only 1/20 of the︀ value of the property when you bought it. You can do this for 20 years.︁
- so if you buy 3 apartments each worth of 200k... you can claim tax︂ expenses 30k every year (for 20 years)
- your tax base will be -6240 eur︃
- after paying CPT (which is now ridiculously high 21%, but will get lower) which︄ will be in your case 0 eur (for at least 20 years) and then 7%︅ dividend tax (which is promised to be abolished again) you will left with 22096 eur.︆
From the whole 30k you should get around 27136 eur to your private bank account︇ (rest will be taxes and social levies). So the effective tax rate will be around︈ 9,54%.
PROS
- You will invest the whole sum (without the 7% loss on dividends︉ from UAE)
- Assets (or 90% at least) protected from marriage etc., bc owned by︊ Seychelles company
- Legally is this setup slightly better than with the UAE
CONS
- If you will decide to sell the property, you will have to pay CPT, as︋ a private individual there is no tax
- If you rent as a private individual︌ you pay 19% tax, as a company you have to pay CPT + dividend tax︍ (which you can minimize through tax expenses)
- When you will sell the property you︎ will have to sell it with VAT + 20%.
- Soon or later will the️ EU push countries like Slovakia adapt some standardized CFC rules (you will have to appoint nominees then or better in the meantime work on getting the slovak company under your full control).
Hello,
Thanks so much for this important input, you seem to know︌ exactly what you are saying and I love this.
You really make think about the︍ whole situation, thanks!
A few points:
1)UAE = Extra EU UAE = 0 Taxes
2)Cyprus Non Resident Company= EU Friendly with VAT Number etc.
3)Seychelles / Belize = Not a︎ good reputation
If 1) 2) 3) will be created and then incorporated in Slovakia then:️
Q1: What happen if those countries will:
A) Increase Taxes
B) Exchange information about the Owner of the company having a EU Pass. As far as I know Western Europeans Tax Authorities are extremely against those entities if there is no substance and are used only to bypass taxations
C) change the exchange agreements, DBA, etc
Q2: Why do you suggest a 90/10 Ownership spliced between business and private?
Lets suppose my LTD (no matter in what country 1) 2) 3)) will get 30K from the rental income:
30,000 Income
6,240 EUR (Director Salary) -
___________
23760 EUR
600,000 / 20 Years = 30,000
-6240 EUR (Business Income)
0 Corporate Taxes
OK
Lets suppose the same company is incorporated in︀ a Western EU country where the corporate tax is for example 25% + 20% -30%︁ divided taxes:
30,000 Rental Income -
28,000 EUR (Directory Salary) -> Approx 18,000 - 20,000︂ NET ((2/3 Income)) after deduction of insurance, retirement account, expenses like director car, some travels,︃ half of the home office surface, etc)
2,000 Other Business Expenses
0,000 EUR (income)
600,000 / 20 Years = 30,000
______
-30,000 EUR (Business Income)= No Divided Taxes = No︄ Corporate Taxes
-> So basically even if the company reside in a high taxation country︅ in Western Europe. the Director can get a salary according to the needs and expenses︆ as there is a fiscal progression and having the Director have some deductible costs, it︇ might be possible to reach a similar result as in Slovakia). This structure will also︈ allow the director to live in a different country (digital nomad) for some times and︉ eventually get back to the homepage in a legit way and by saving a lot︊ of taxes.
Let me know your comments on this, thanks!
Thanks so much for this important input, you seem to know︌ exactly what you are saying and I love this.
You really make think about the︍ whole situation, thanks!
A few points:
1)UAE = Extra EU UAE = 0 Taxes
2)Cyprus Non Resident Company= EU Friendly with VAT Number etc.
3)Seychelles / Belize = Not a︎ good reputation
If 1) 2) 3) will be created and then incorporated in Slovakia then:️
Q1: What happen if those countries will:
A) Increase Taxes
B) Exchange information about the Owner of the company having a EU Pass. As far as I know Western Europeans Tax Authorities are extremely against those entities if there is no substance and are used only to bypass taxations
C) change the exchange agreements, DBA, etc
Q2: Why do you suggest a 90/10 Ownership spliced between business and private?
Lets suppose my LTD (no matter in what country 1) 2) 3)) will get 30K from the rental income:
30,000 Income
6,240 EUR (Director Salary) -
___________
23760 EUR
600,000 / 20 Years = 30,000
-6240 EUR (Business Income)
0 Corporate Taxes
OK
Lets suppose the same company is incorporated in︀ a Western EU country where the corporate tax is for example 25% + 20% -30%︁ divided taxes:
30,000 Rental Income -
28,000 EUR (Directory Salary) -> Approx 18,000 - 20,000︂ NET ((2/3 Income)) after deduction of insurance, retirement account, expenses like director car, some travels,︃ half of the home office surface, etc)
2,000 Other Business Expenses
0,000 EUR (income)
600,000 / 20 Years = 30,000
______
-30,000 EUR (Business Income)= No Divided Taxes = No︄ Corporate Taxes
-> So basically even if the company reside in a high taxation country︅ in Western Europe. the Director can get a salary according to the needs and expenses︆ as there is a fiscal progression and having the Director have some deductible costs, it︇ might be possible to reach a similar result as in Slovakia). This structure will also︈ allow the director to live in a different country (digital nomad) for some times and︉ eventually get back to the homepage in a legit way and by saving a lot︊ of taxes.
Let me know your comments on this, thanks!
I know that people in the neighbor Czech Republic have closed their offshore corps due to inefficiency. The laws there are pretty the same
Yes, it's bulletproof but costs quite a︀ lot.
Tax authorities will definitely have a solution to get any︅ information even if no DTT exists, they simply get the information from AEOI or direct︆ request to bank.
Is Cyprus non resident company allowed to buy property in︈ EU? And if yes, is this a solution not to setup a local company in︉ Slovakia?
Yes, it's bulletproof but costs quite a︀ lot.
Tax authorities will definitely have a solution to get any︅ information even if no DTT exists, they simply get the information from AEOI or direct︆ request to bank.
Is Cyprus non resident company allowed to buy property in︈ EU? And if yes, is this a solution not to setup a local company in︉ Slovakia?
2) A Cyprus non-resident company can not have a VAT number, but sure the EU company looks better...
3) Yeah, I forgot that your clients may have problem with paying invoices to Seychelles/Belize
In the case you would go through a cyprus non-resident company, you would just invoice your clients... then appoint a Cyprus director to access double tax treaties and pay yourself all income through dividends in Slovakia (taxed 7%)... you would continue investing as a private individual like suggested in my innitial post with the UAE FZE company.
A.) Any country can raise taxes, incl. Slovakia, Poland, France or Spain. Central European countries︀ do have lower productivity than their Western European counterparts so the lower taxes are essential︁ to maintain competitiveness to attract foreign investments, therefore they will not ruin their business model.︂ You can look at average annual GDP growth in Czechia, Slovakia or Poland and their︃ debt to GDP ratio levels and you get a clear picture that they do not︄ have to raise taxes... unlike Western European countries.
B.) / C.) In the case of︅ Slovakia this will not be an issue, bc of no CFC rules for private individuals,︆ so as a slovak tax resident you can bypass whatever you want. The only issue︇ can be as GrumpyMess mentioned "A company is resident if its seat or place of︈ effective management is in Slovakia". In the case of a Cyprus non-resident with Malta office︉ and director it is clear bc effective management is in Malta. If the UAE will︊ change its laws and they will release who is 100% shareholder/director, I wish good luck︋ to slovak tax authorities to prove where was the effective management when the profit was︌ made (bc no accounting in UAE companies etc.)... and frankly this is scify. A couple︍ weeks ago they caught a guy with 500k in cash, who has officially on his︎ pay roll 1k eur income, and they had to let him go bc he said️ "I found the bag with money in the house of my grandmother, which passed a few years ago".
Q2: Because you need to have some share capital in the slovak company to get dividends with the 7% rate, otherwise it would be 19%.
In my Seychelles/Slovakia setup you get 27k from 30k, in your domestic country it would be 20-21k from 30k. In your first post you stated live from 2-3k month / offshore, so this could make a difference.
Do you mind sharing which country are you in now? 25%, I suppose Netherlands?
3) Yeah, I forgot that your clients may have problem with paying invoices to Seychelles/Belize
In the case you would go through a cyprus non-resident company, you would just invoice your clients... then appoint a Cyprus director to access double tax treaties and pay yourself all income through dividends in Slovakia (taxed 7%)... you would continue investing as a private individual like suggested in my innitial post with the UAE FZE company.
A.) Any country can raise taxes, incl. Slovakia, Poland, France or Spain. Central European countries︀ do have lower productivity than their Western European counterparts so the lower taxes are essential︁ to maintain competitiveness to attract foreign investments, therefore they will not ruin their business model.︂ You can look at average annual GDP growth in Czechia, Slovakia or Poland and their︃ debt to GDP ratio levels and you get a clear picture that they do not︄ have to raise taxes... unlike Western European countries.
B.) / C.) In the case of︅ Slovakia this will not be an issue, bc of no CFC rules for private individuals,︆ so as a slovak tax resident you can bypass whatever you want. The only issue︇ can be as GrumpyMess mentioned "A company is resident if its seat or place of︈ effective management is in Slovakia". In the case of a Cyprus non-resident with Malta office︉ and director it is clear bc effective management is in Malta. If the UAE will︊ change its laws and they will release who is 100% shareholder/director, I wish good luck︋ to slovak tax authorities to prove where was the effective management when the profit was︌ made (bc no accounting in UAE companies etc.)... and frankly this is scify. A couple︍ weeks ago they caught a guy with 500k in cash, who has officially on his︎ pay roll 1k eur income, and they had to let him go bc he said️ "I found the bag with money in the house of my grandmother, which passed a few years ago".
Q2: Because you need to have some share capital in the slovak company to get dividends with the 7% rate, otherwise it would be 19%.
In my Seychelles/Slovakia setup you get 27k from 30k, in your domestic country it would be 20-21k from 30k. In your first post you stated live from 2-3k month / offshore, so this could make a difference.
Do you mind sharing which country are you in now? 25%, I suppose Netherlands?
I know guys who still run funds through BVI and pay themselves small salaries through CZ companies. They have never paid any CPT in CZ. Most closed bc CZ now also offer holding regime if the classic conditions are met, but for online business is offshore still essential. Depends on scale. On small scale you rather pay 19% than costly structures.
Yep
Yes, they just do not do it. As you can see in the︀ picture. One particular bank "Postova Banka" encourages its clients to setup companies in Cyprus, they︁ lent to such Cyprus non-resident setups owned by their clients (95% Slovaks) money worth of︂ more than 3bln eur to this day, 25% of all money they lent. They normally︃ do business through those companies and pay no taxes.
I do not know this.︆
Btw. You mentioned the micro Romanian company with 3%. Do you know about VAT rules︇ in Romania? A software company selling software (digital sales) to final customers outside the EU.︈ So B2C transactions, outside of the EU (Asia, South America, North America). Does this company︉ have to charge VAT on such transactions?
Yep
Yes, they just do not do it. As you can see in the︀ picture. One particular bank "Postova Banka" encourages its clients to setup companies in Cyprus, they︁ lent to such Cyprus non-resident setups owned by their clients (95% Slovaks) money worth of︂ more than 3bln eur to this day, 25% of all money they lent. They normally︃ do business through those companies and pay no taxes.
I do not know this.︆
Btw. You mentioned the micro Romanian company with 3%. Do you know about VAT rules︇ in Romania? A software company selling software (digital sales) to final customers outside the EU.︈ So B2C transactions, outside of the EU (Asia, South America, North America). Does this company︉ have to charge VAT on such transactions?
No it's not possible to register a non resident Cyprus company for VAT!
I would not bet my last coin on that, sorry but this is too weak.
I would not bet my last coin on that, sorry but this is too weak.
Hello Friend!
What I LIKE from︀ your schema:
UAE / Belize / Seychells = No Taxes
SK = 7% Dividend
What I DO NOT LIKE:
Uncertain Future:
A) Tax Authorities of Western Countries can be really︁ aggressive if they see that a national is trying to use this kind of structure︂
B) Also there is an inversion of the proof in case of claim, the Director︃ will need to demonstrated that this structure has a substance which is not easy for︄ certain reasons
Under my schema, even if Netherlands charge 25% Corporate Taxes and high dividends︅
30,000 Rental Income -
28,000 EUR (Directory Salary) -> Approx 18,000 - 20,000 NET ((2/3︆ Income)) after deduction of insurance, retirement account, expenses like director car, some travels, half of︇ the home office surface, etc)
2,000 Other Business Expenses
0,000 EUR (income)
600,000 / 20︈ Years = 30,000
-> My above “local” scenario Is GOOD if we only consider that︉ there is no risk with local authorities, relocation (if I am going for digital nomad)︊ a few years, decent social service, insurance, pension etc,no stress worries about new DBA, common︋ reporting agreements, etc.
->My scenario is really BAD if the local LTD will be selling︌ the properties as the money will still be inside the LTD and the only way︍ to get it out is by paying to the Director (myself) salaries (where I need︎ to deduct social costs, pension, etc) or by paying HUGE dividends on it.
I do️ not see any reason why the LTD should be liquidated and sell the properties but with your SK scenario the pain would be just 7%.
What do you think about this?
What I LIKE from︀ your schema:
UAE / Belize / Seychells = No Taxes
SK = 7% Dividend
What I DO NOT LIKE:
Uncertain Future:
A) Tax Authorities of Western Countries can be really︁ aggressive if they see that a national is trying to use this kind of structure︂
B) Also there is an inversion of the proof in case of claim, the Director︃ will need to demonstrated that this structure has a substance which is not easy for︄ certain reasons
Under my schema, even if Netherlands charge 25% Corporate Taxes and high dividends︅
30,000 Rental Income -
28,000 EUR (Directory Salary) -> Approx 18,000 - 20,000 NET ((2/3︆ Income)) after deduction of insurance, retirement account, expenses like director car, some travels, half of︇ the home office surface, etc)
2,000 Other Business Expenses
0,000 EUR (income)
600,000 / 20︈ Years = 30,000
-> My above “local” scenario Is GOOD if we only consider that︉ there is no risk with local authorities, relocation (if I am going for digital nomad)︊ a few years, decent social service, insurance, pension etc,no stress worries about new DBA, common︋ reporting agreements, etc.
->My scenario is really BAD if the local LTD will be selling︌ the properties as the money will still be inside the LTD and the only way︍ to get it out is by paying to the Director (myself) salaries (where I need︎ to deduct social costs, pension, etc) or by paying HUGE dividends on it.
I do️ not see any reason why the LTD should be liquidated and sell the properties but with your SK scenario the pain would be just 7%.
What do you think about this?
As a general rule in EU export of such services outside of the EU is VAT-free, the same applies to Romania
What about this one:
- Move to Cyprus, apply for non-dom tax residence for you as a private person. Rent a flat/house for 2-3 months to make it 100% legal and bulletproof and dont live anywhere else for more than 183days...
- Create LLP in UK and invoice from UK
- As tax resident of Cyprus you will pay zero tax but consult this setup with a tax advisor first.
The fee to setup a UAE companu is roughly 12,000 euro and 15,0000 per year! Why would someone go that route unless you have millions available?
Hello,
In my︋ opinion, Netherlands is one of the better options in the West to be incorporated. There︌ are two CPT brackets, so you will pay 25% only on the profit above 200k,︍ rest will be taxed with 20%. On the top, the local government approved tax cuts,︎ so you should be taxed actually this way through Dutch LTD.
2019: 400k profit -️ effective rate 22%
2020: 200k profit - effective rate 16,5%
2021: 100k profit - effective rate 15%
Until you will be a tax resident of Netherlands, you will have to pay high taxes on a personal level one way or the other if you decide to sell the company or through dividends. However, it will probably happen in a very long time from now (sell of the properties), in the future which is uncertain and many things can happen until that time. Both positive and negative. You can change your tax residency then (I do not know how will Dutch tax authorities look at you,︀ then tho).
Is it essenatial to own a physical real estate for you?
What I︁ would persnally do... get tax residency in some no-CFC rules country. Open Seychelles/Belize/UAE/BVI... company and︂ invoice clients. With profits I would buy REIT stocks (if real estate is desired) and︃ dividends from stocks I would cashed through a corporate card at ATM and lived in︄ cash... and pay no taxes at all anywhere.
Once the money will hit the EUSSR,︅ they will squeeze you... more or less everywhere.
Btw. I am myself in the process︆ of buying a property in NL and LOL. 6% real estate transfer tax. I do︇ not want to know the yield if I would decide to rent.
In my︋ opinion, Netherlands is one of the better options in the West to be incorporated. There︌ are two CPT brackets, so you will pay 25% only on the profit above 200k,︍ rest will be taxed with 20%. On the top, the local government approved tax cuts,︎ so you should be taxed actually this way through Dutch LTD.
2019: 400k profit -️ effective rate 22%
2020: 200k profit - effective rate 16,5%
2021: 100k profit - effective rate 15%
Until you will be a tax resident of Netherlands, you will have to pay high taxes on a personal level one way or the other if you decide to sell the company or through dividends. However, it will probably happen in a very long time from now (sell of the properties), in the future which is uncertain and many things can happen until that time. Both positive and negative. You can change your tax residency then (I do not know how will Dutch tax authorities look at you,︀ then tho).
Is it essenatial to own a physical real estate for you?
What I︁ would persnally do... get tax residency in some no-CFC rules country. Open Seychelles/Belize/UAE/BVI... company and︂ invoice clients. With profits I would buy REIT stocks (if real estate is desired) and︃ dividends from stocks I would cashed through a corporate card at ATM and lived in︄ cash... and pay no taxes at all anywhere.
Once the money will hit the EUSSR,︅ they will squeeze you... more or less everywhere.
Btw. I am myself in the process︆ of buying a property in NL and LOL. 6% real estate transfer tax. I do︇ not want to know the yield if I would decide to rent.
- Status