Possible Offshore Structure Idea

[ernestdezoe]

Ok but in what sense? What's the trigger for‌ the transfer? Money arriving in a Maltese bank account or just the funds being in‍ the availibility of the person or company which is resident in Malta ?

Because if⁠ that's the case good luck policing a guy making say 500k/yr and prevent him to⁤ spend in Malta, especially during the summer.

This seems what OP is trying to do⁣ with a bank account in the US and him staying in Malta.

Again, one of⁢ those rules born out of a beurocrat who has never been on the other side︀ of the fence and never had to plan for , nor enforce the thing he︁ just wrote

 

[Marzio]

If you transfer those money to Malta they are obviously remitted to Malta but then‌ again money sitting in a Swiss bank account under your name that you spend with‍ bank's debit card in Malta are remitted or not? Who knows!

That's exactly the reason⁠ why if your offshore company makes > 35K you have to pay 5K taxes.

They are happy because they get their share of money and you are happy because you⁤ know nobody will come after you.

 

[uplana]

if that is the case I would‍ not waste time discussing or hiding a lot. Pay the 5K and keep up the⁠ good work.

 

[Marzio]

I highly advise to check with a professional. Also remember‍ that the offshore company is considered a CFC but it will be exempt if profits⁠ are < 750K and passive income <75K. Make your calculations.

 

[ciccino]

So if I will reach⁠ 750 with my LLC I have to open another one to avoid CFC?

 

[Marzio]

In that case all the CFC’s will‍ be in your name so the amount over 750k will be taxed.

 

[ciccino]

This will be easily solved moving‍ the residence to Malta or Panama, isn't that so?

 

[Marzio]

Moving to Panama would solve the problem.

 

[ciccino]

Too far away,‌ Malta, Romania or San Marino could be a possible option for me.

 

[Marzio]

Then go for it. You could get away with 7% tax for 15 years but you‌ have to deal with some account to set things up.

 

[uplana]

That would be okay, if you can legally pay only 7% then some accounting⁠ stuff should not stop you, outsource it and move foward.

 

[Brillo]

I have your similiar situation, and i picked Romania. Have‍ already rented an apartment and I will move there in 2 weeks
culture quite similar⁠ to our Italian, very honest cost of living, and 1.55h flight time to Italy.

I was going for Malta than i said: "why i'm really leaving Italy"? Because I want⁤ to go to a country where I can save and then reinvest ... so the⁣ most logic choice was Romania as Malta is quite expensive

San Marino won't give you⁢ residence unless you spent something like 500.000€ or you marry someone there or, you hire︀ 3 San Marino employers in your SM company

 

[thirtyniner]

Or someone with an offshore account in an English speaking country!⁠ "Remittance" is more common then "Transfer".

 

[Marzio]

That’s not the case. There’s a new kind of residency that can⁠ be obtained without having to start a company there, invest money or hire people.

 

[Brillo]

Feel free to share source of that, because I cannot see anything like that⁠

 

[Marzio]

Here

 

[uplana]

Not bad, had a very good read and wonder‌ if someone is going to set this up?

 

[Brillo]

That's an old program.
Anyway, it's like flat-rate scheme‌ in Italy. you have a maximum limit of 100.000€ annually... so only for small business‍

 

[Marzio]

This residency program was introduced in‌ January 2021

It is not. In Italy you pay 100K flat, in S.Marino you pay 7% starting with‍ 10K minimum.

 

[Brillo]

yes but with 100.000€ maximum, that's what I was saying