Based on what? I know for a fact that I can get a Portuguese holding (SGPS) with a Madeira subsidiary and retain or reinvest the profits by constituting other subsidiaries, tax free. With the EU freedom of establishment for companies, if I can have it in Portugal I can also have it in another EU country. If︀ you can show otherwise, I'm all ears.
Madeira Free Trade Zone (Portugal)
- Thread starter Super Tucano
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So you are setting up a structure with a corporate tax law that lasts only 7 years and a NHR residency status that lasts only 10 years. Add to this you will be attempting a tax avoidance structure where anti-abuse clauses mean the tax authority may disregard transactions where the main purpose is to eliminate or reduce taxes. Plus EU ATAD has come into effect. I mean what could go︀ wrong...lol. It sounds a good intermediate plan with risk for max 7 years but the︁ devil is in the detail.
I have looked a bit into the whole NHR thing. I would not do it. There is so much uncertainty associated to it (CFC rules, anti-avoidance rules etc.), there is the limited time frame, but most of all, it seems like Portuguese bureaucracy is an absolute NIGHTMARE. Talk to some Portuguese people, they will tell you it's hell on earth.
What good is it if a structure might work in theory (or maybe not, depending on what the tax office decides later), when you can't get an advance ruling (because they don't look at hypothetical cases), when you can't do anything without a lawyer etc.︀ etc.
You'll want very clear, established rules, with many precedents, not some complicated structure with︁ lots of ifs and buts.
What good is it if a structure might work in theory (or maybe not, depending on what the tax office decides later), when you can't get an advance ruling (because they don't look at hypothetical cases), when you can't do anything without a lawyer etc.︀ etc.
You'll want very clear, established rules, with many precedents, not some complicated structure with︁ lots of ifs and buts.
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