Hello from Sweden! Complicated situation
- Thread starter GORDY
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id be very surprised if this is the case. Its an european country and they will have double tax treaties. Likewise the OP is outside sweden from what i understand, therefore the companies are no longer Swedish tax resident as the management and control has moved with the new owner. Same way as Sweden would like to tax offshore vehicles owned by swedish resident people, the other way goes as well. The tax residency of the company moves︀ with the owner.
I can for example establish a business in sweden, but not be︁ tax resident, since i never set a foot inside sweden
I can for example establish a business in sweden, but not be︁ tax resident, since i never set a foot inside sweden
Yes there are double tax treaties sure, but the owner of a Swedish business (direct or indirect) would still be considered to have a significant tie to Sweden and thus to be a Swedish tax resident in this case. Then if the the owner lives in a country with a double tax treaty with Sweden, that tax treaty would probably make it so this person would mainly pay tax in this other country. I believe the OP wanted to live︀ in the UAE though, and there is no double tax treaty between Sweden and the︁ UAE.
We are talking about the tax residency of︆ the individual person owning the company here, not of the company itself.
Well, if someone who has never︈ lived in Sweden and isn't a Swedish citizen owns a Swedish business, then I think︉ tax authorities would look at the full situation and deem that just the business ownership︊ wasnt a sufficient tie to Sweden, and decide that this foreign owner is not a︋ Swedish tax resident. Im not 100% sure though.
We are talking about the tax residency of︆ the individual person owning the company here, not of the company itself.
Well, if someone who has never︈ lived in Sweden and isn't a Swedish citizen owns a Swedish business, then I think︉ tax authorities would look at the full situation and deem that just the business ownership︊ wasnt a sufficient tie to Sweden, and decide that this foreign owner is not a︋ Swedish tax resident. Im not 100% sure though.
CH wouldn't say that much︁ provided the person setting it up has strong ties to the DRC. Ive seen this︂ IRL and it didn't cause problems. If you dont have any ties to the DRC︃ then it might be frowned upon, yet when you incorporate an AG the authorities wouldn't︄ really see that much. Only your CH bank would.
Only option I see is to incorporate a new company in a low tax country. Bring IP into that company and license the IP to the Swedish Holding. You then shift some of your profits (within the limits of what is allowed) to low tax.
For as long as the Swedish group still depend on you... you will still be taxed on the offshore profits (as mentioned before) unless you cut ties permanently. I know first hand that this is next to impossible and if you want to follow that route you will even be severely limited in︀ how often you can visit Sweden.
Only option I see is to incorporate a new company in a low tax country. Bring IP into that company and license the IP to the Swedish Holding. You then shift some of your profits (within the limits of what is allowed) to low tax.
For as long as the Swedish group still depend on you... you will still be taxed on the offshore profits (as mentioned before) unless you cut ties permanently. I know first hand that this is next to impossible and if you want to follow that route you will even be severely limited in︀ how often you can visit Sweden.
This is not about becoming tax resident, but about remaining tax resident. You would remain tax resident under domestic rules. So if you were living in Sweden before and move to the UAE (no tax treaty) and still own the Swedish company in any way - you remain Swedish tax resident under domestic rules.
But what I don't understand is: Why would domestic rules matter if there is a tax treaty?
Just move to Estonia (tax treaty country) and pay yourself dividends from the Swedish holding company (or possibly, set up an Estonian holding company), cash out totally tax free.︀
Or Cyprus or Malta should work, too, I guess they have tax treaties with Sweden︁ as well (didn't check).
But what I don't understand is: Why would domestic rules matter if there is a tax treaty?
Just move to Estonia (tax treaty country) and pay yourself dividends from the Swedish holding company (or possibly, set up an Estonian holding company), cash out totally tax free.︀
Or Cyprus or Malta should work, too, I guess they have tax treaties with Sweden︁ as well (didn't check).
No, I don't think that would work. Maybe if you live in Estonia for 10+ years or so, but not if you only stay there for one year.
With tax-aggressive countries like that, you should stay in countries that have a tax treaty.
Stay in Estonia/Cyprus/Malta for as long as you have ties to Sweden (local company). After you have closed the companies, move to the UAE. Or to some other country.
Or just move to Thailand (tax treaty country, no tax on︀ foreign income that isn't remitted to Thailand).
There really are lots of options. Just make︁ sure there is a treaty.
With tax-aggressive countries like that, you should stay in countries that have a tax treaty.
Stay in Estonia/Cyprus/Malta for as long as you have ties to Sweden (local company). After you have closed the companies, move to the UAE. Or to some other country.
Or just move to Thailand (tax treaty country, no tax on︀ foreign income that isn't remitted to Thailand).
There really are lots of options. Just make︁ sure there is a treaty.
I agree.
From my network I am aware of a case where︀ a Swedish national moved to Cyprus and got the family assets in his name as︁ to mitigate the tax exposure in Sweden. I remember that he had to be very︂ strict on how many days he physically was present in Sweden. Sweden is very strict,︃ kind of similar to all the other high tax countries.
From my network I am aware of a case where︀ a Swedish national moved to Cyprus and got the family assets in his name as︁ to mitigate the tax exposure in Sweden. I remember that he had to be very︂ strict on how many days he physically was present in Sweden. Sweden is very strict,︃ kind of similar to all the other high tax countries.
I think that usually shouldn't be an issue if you spend 183+ days in Cyprus - because there is a tax treaty. It would be a completely different situation if you were living︀ in the UAE, which doesn't have a treaty.
Let's say Swedish persons moves to Portugal and don't go never to Sweden. How can they check if he have been 180+ days in Portugal? Portugal is in Schengen area. No border checks.
I think most problems arise then the person try to fake residence in other country and really remain living in Sweden. This is 99,99% of cases︀
I think most problems arise then the person try to fake residence in other country and really remain living in Sweden. This is 99,99% of cases︀
Portugal doesn't have a tax treaty with Sweden (anymore), so it's a bad example. 😉
Yes, of course it's bad when you claim you live in another country, but you actually keep living there.
However, if you look at the link that was posted, it says for the first five years after you move out, you have to prove you don't have any ties to Sweden, no company ownership, nothing. (If you are a Swedish citizen or if you have been Swedish tax resident for 10+ years.) After the first five years, the tax authority would have to prove it.
So it's really easy for them. Unless you can prove you've stayed in the other country for 183+ days, in which︀ case the tie-breaker should save you.
Yes, of course it's bad when you claim you live in another country, but you actually keep living there.
However, if you look at the link that was posted, it says for the first five years after you move out, you have to prove you don't have any ties to Sweden, no company ownership, nothing. (If you are a Swedish citizen or if you have been Swedish tax resident for 10+ years.) After the first five years, the tax authority would have to prove it.
So it's really easy for them. Unless you can prove you've stayed in the other country for 183+ days, in which︀ case the tie-breaker should save you.
Flight tickets. They claim that you are in the country and force you to proof that you weren't. You are then obliged to disclose everything. Based on agreements they would get access to all your bank accounts. From there the travel︀ pattern becomes clear.
If you drive your car around and don't have your smart phone or other leaking device with you, it is passible to drive around without traces. Or at least almost.
Don’t get a speeding ticket with your car. Doesn’t matter whether it’s a rental or owned.
Pay in cash for fuel. And hope that your home country doesn’t have toll roads where cameras are used.
Only then, for a limited amount of time, you might have a chance.
Pay in cash for fuel. And hope that your home country doesn’t have toll roads where cameras are used.
Only then, for a limited amount of time, you might have a chance.
You can move out of EES/EU, make your tax returns in Sweden and the other tax residency country for a few years (5-7), and Sweden will release you from taxing in Sweden. This works even if you own the stocks in a Swedish AB and sit in the board.
During the time you are a tax resident in Sweden and before you move out, it is important to choose your new tax residency country wisely, for example outside of EU/EES and with a tax treaty that will server your purpose.
If you want to, you could create a holding company in a different EU country,︀ sell your stocks to that company and transfer any (taxed) dividend profits there (but beware,︁ this is becoming a limited option as well, check for yourself, don't trust anyone on︂ this). The reason for doing this is that you found a tax treaty between your︃ new tax residency country and the EU country that will lower the taxes on the︄ dividends paid out. Either to yourself as a person or another company (holding). Do an︅ excel table and setup countries, check taxes, etc. Don't forget to check on the "bang︆ for buck" tax concept - what do you get for the taxes, although paying less,︇ in your new tax residency - better or not?
The cost of all this is︈ that once you leave EU and Sweden your possibility to be in control of the︉ company/companies through the board of directors will be limited. You will have to rely on︊ other people that are living in Sweden (and EU) to be on the board.
As a FOREIGN owner (UBO) of a Swedish AB the Swedish banks will f**k you so︋ hard and after that thank you by closing your company accounts - and you will︌ need to look into other banks outside of Sweden (and forget about bankgiro). Unless you︍ have a lot of dough to deposit or find some smaller Swedish bank that needs︎ your revenue, it may be very cumbersome.
The politicians in EU (and very much so️ in Sweden) will do everything to squeeze out any additional tax income and money leaking out of the country by using the banks, hiding behind the "money laundry"-concept and through in some stupid terrorism financing concept. The bank systems are just used by the politicians to get at the "little man" - I still have not heard of any of the big banks in Sweden that have not performed or are not performing money laundry. It's a joke (although not funny one).
It's definitely possible, but be aware of loosing your hair (unless you lost it already) ;-) And regarding accountants and tax lawyers -︀ you need a good one in each country and you should be very good at︁ asking the right questions (eg. don't trust them).
But once you arrive where you want︂ to be, it can be a pretty nice place to be in (compared to Sweden)︃ 😎
During the time you are a tax resident in Sweden and before you move out, it is important to choose your new tax residency country wisely, for example outside of EU/EES and with a tax treaty that will server your purpose.
If you want to, you could create a holding company in a different EU country,︀ sell your stocks to that company and transfer any (taxed) dividend profits there (but beware,︁ this is becoming a limited option as well, check for yourself, don't trust anyone on︂ this). The reason for doing this is that you found a tax treaty between your︃ new tax residency country and the EU country that will lower the taxes on the︄ dividends paid out. Either to yourself as a person or another company (holding). Do an︅ excel table and setup countries, check taxes, etc. Don't forget to check on the "bang︆ for buck" tax concept - what do you get for the taxes, although paying less,︇ in your new tax residency - better or not?
The cost of all this is︈ that once you leave EU and Sweden your possibility to be in control of the︉ company/companies through the board of directors will be limited. You will have to rely on︊ other people that are living in Sweden (and EU) to be on the board.
As a FOREIGN owner (UBO) of a Swedish AB the Swedish banks will f**k you so︋ hard and after that thank you by closing your company accounts - and you will︌ need to look into other banks outside of Sweden (and forget about bankgiro). Unless you︍ have a lot of dough to deposit or find some smaller Swedish bank that needs︎ your revenue, it may be very cumbersome.
The politicians in EU (and very much so️ in Sweden) will do everything to squeeze out any additional tax income and money leaking out of the country by using the banks, hiding behind the "money laundry"-concept and through in some stupid terrorism financing concept. The bank systems are just used by the politicians to get at the "little man" - I still have not heard of any of the big banks in Sweden that have not performed or are not performing money laundry. It's a joke (although not funny one).
It's definitely possible, but be aware of loosing your hair (unless you lost it already) ;-) And regarding accountants and tax lawyers -︀ you need a good one in each country and you should be very good at︁ asking the right questions (eg. don't trust them).
But once you arrive where you want︂ to be, it can be a pretty nice place to be in (compared to Sweden)︃ 😎
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