Incorporate in Estonia, Residence in Malta

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Dividends will always first be taxed in Estonia, then potentially a second time somewhere else.‌ The way they do that is that it’s officially not a tax on dividends, but‍ a deferred corporate income tax. Estonia is not a tax haven.
 
If you work from Malta, the income will probably be considered as locally sourced and‌ subject to Maltese tax. But I don’t know a lot about Malta. This setup just‍ doesn’t seem like a very good idea to me.
Why do you want to move⁠ to Malta?
 
is that really required. If you have to spend 50K you⁠ will need to have a big business there otherwise it looks like not making much⁤ sense.
 
Just have company and residency in Estonia and live in Malta without visa. If you‌ are EU citizen of course.
 
do you intend to also‍ take personal residence in Estonia and remove the Maltese one?
 
Why don't you simply set up your business in Malta? Normally a Maltese company that‌ owns a Maltese company in Malta will only have like 5% total corp tax rate..‍ isn't there a way to make it 5% total here, no additional personal taxes for⁠ the Maltese resident?

Also, with your suggested Estonia setup, if you would spend 179 days⁤ a year operating that business from Estonia and have 183 days a year vacation in⁣ Malta, I'm thinking the classification that the Estonia business "would be taxed in Malta too"⁢ should not apply, though not sure - anyone thouhgts?

Tax Cow, what in the Estonia-Malta DTA is it you are thinking of, is there some︆ company tax residency clause in there, what does it say?

Anyhow off hand I don't︇ understand why Estonia is needed at all if you're going to Malta anyhow, which has︈ good structural options already.
 
I think people are overthinking the issue. If he moves to Malta just stay below‌ the CFC threshold and declare everything.
 
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