Martin Everson said:
Depends whether you mean escape as an individual or as a company?
Click to expand...
Sorry I should have been more specific. I guess I meant exiting the EU compliance overhead, or bringing it down to near zero.
So that I can dispose of the EU company part if the situation calls for it, having shifting retained earnings entirely over time.
Cyprus companies are usually good as holding companies, but in this instance, the Cyprus company should be wholly owned by another entity that will receive the past retained earnings in yearly tranches of dividends.
I would assume this works because Cyprus has no dividend withholding, although I'm not clear on whether paying out dividends out of retained earnings that are older than 1 year old is OK tax wise.
Also the jurisdiction of the holding company then matters (it should ideally not tax those incoming dividends), and there lies the nexus of my question: what are the setups (read: ideal target jurisdictions for my example of a CY company) that allow this orderly exit over time.
After that, the Cyprus company is a ghost of its former self, and can be disposed of rather easily. If one still needs an EU VAT ID, the company can be retained, as long as the maintenance costs (audit and accounting) are not prohibitive.
I think it would be a good idea to have pinned posts that document common patterns so that people who have access to counsel can fact check them for the benefit of others. I for example am fact checking the US-CY and CY-only pattern for Amazon US FBA (which will take time), and will soon fact check the CY-Winddown pattern, with diagrams and stuff like that. But I don't have a good place to put this in.
