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How to Avoid CRS - 3 Options as of 2019 - 2025

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Two more questions on CRS, to which I couldn't find an answer:
1) in the‌ past, when a country signed on to CRS, was there time to move away money‍ before the first message is sent?I mean, if TransferWise decides to start reporting to CRS,⁠ will there be time to close the account and not be reported?
2) If I⁤ have a bank account which is opened by the director of the company, will the⁣ bank report the director or the Beneficiary Owner of the company?
 
The agreements typically involve start reporting on a future date, but sending data from⁣ previous years. So there is no escape by closing your account.

The bank will report⁢ what they know. Of course the UBO as well as the director.
 
The only way to forget CRS problematics is relocation to 0% income tax country. Change‌ your residency and forget it.
If you are anywere mentioned on the documents of company‍ or as UBO you would not avoid it.
 
Usually you cannot‌ avoid "effective place of management" rulings even if no CFC. It's the case with countries‍ like Singapore, Cyprus, Malta etc.
 
That's really‍ on a case by case basis, it depends what you define as "management", which of⁠ course varies from company to company. In a service company, where for example you sell⁤ web development services to other companies, the management level basically signs contracts, which can be⁣ done by the nominee director, while the actual service, the development, can be externalized to⁢ freelancers. So it's possible to demonstrate that the management is actually off-shore, I'm not 100%︀ sure that this will resist when you go to court, but it can be discussed.︁
The issue with 0% income tax countries is that moving to that country might not︂ be as easy, so for example in Italy if you move to a 0% tax︃ country, and the tax authority decide that the move is only for tax evasion purposes,︄ it's up to you to prove that the residency is real and not up to︅ them to demonstrate that it's fake. ( There is debate if that violates constitutionals right,︆ but that's it ). And if you move to a country and can demonstrate that︇ the move is real, but you have a family in Italy, you're considered resident in︈ Italy, so you have to move wife and children. While if you move to Spain︉ or Germany nobody will say anything, and once you've been outside of your home country︊ for some years, you can move to a 0% tax country more easily.
One last︋ thing to note is that CFC rules are different in every country, so for example︌ in italy, to be considered cfc, the company must have at least 25% of passive︍ income, while it's 15% in Spain.
So I'm not saying that one thing is better︎ than the other, but that everything depends on a lots of factors 😀
 
@zsars

With a quick google search, seems real︉ estate prices in Tbilisi are pretty reasonable, so this could be an option but may︊ be overkill? As I'm only looking to move between 500k and 800k.

Essentially what would︋ be the quickest, safest way to move the money from the Spanish company account to︌ my US LLC?

I want to have access to the money personally and to use︍ it to invest in Latin American real estate through local companies that will be owned︎ my Wyoming LLC. I will have Panamanian residency as a British citizen but my main️ worry is getting flagged by the Spanish non-resident income tax, for pulling the money out‌ of the company.
 
It's more like the same everyplace. If you move to tax︎ free country you are still considered resident for some time 2-5 years. Does UAE, Andorra,️ Monaco include in Italy black list?
 
yes they are all in the blacklist. Of⁠ course they can't check everybody, they start with those who emigrate and were big taxpayers.⁤ For example there was a Soccer player, Vucinic, that went to play in UAE, but⁣ left his wife and kids in Italy, and when he came back to Italy, he⁢ was sanctioned and his gains were taxed.
 
The quicker and‍ easier you want it, the more risk you take. This is similar to the "service⁠ dilemma": we all want - cheap, fast delivery, high quality. But we can only pick⁤ 2, never all 3.

500-800K is not low enough to go unnoticed.

For quicker, cheaper,⁣ but riskier, establish a WY LLC with your Spanish company and yourself as members. Inject⁢ 500-800K from the Spanish company to WY LLC as capital contribution. Then later down the︀ road make adjustments in beneficial ownership. Become the sole owner of WY LLC.

In case︁ of an investigation, the tax office would want to see that you acquired Spanish company's︂ interest in WY LLC at a fair market value (arm's-length principle). But if there's no︃ investigation, you can get away with buying it for $1.
 
So since the US is trying to establish them self as one of the biggest‌ offshore countries, has their FATCA and don't give a s**t about CRS the best option‍ from what I understood is basically having a US LLC and being tax resident in⁠ one of the low / zero tax countries?
 
Thanks again.

Leaning more towards the Georgia idea or maybe a mix︃ of both. Could you PM the bank names in Georgia?
 
Thats the⁤ route I have taken. Only certain states in the US have low/no taxes, mainly people⁣ use Delaware, Wyoming or Nevada.
 
Well since LLC‍ is passing through the tax to you as a person and I am living in⁠ GCC since few years its fine.
 
Even better if your 2nd residency country has no agreements to receive any information. It‌ never gets sent back.
 
I'm not so sure. I'm guessing‍ that being resident in a low/no-tax jurisdiction or a no-CRS jurisdiction in itself could trigger⁠ a bank to dig deeper to find a reasonable place to send information to.
 
What do personal accounts typically require nowadays?⁣ Is it enough to just show them some rental deed and a utility bill? They⁢ don't ask for any other proof of actual tax residency in the said country? (Like︀ say a tax certificate or a recent declaration etc.)
 
In Georgia it's only your passport, which may not⁤ be from "undesired" countries.
 
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