Romanian SRL micro-enterprise dividends + Cyprus non-dom ?
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I have lived there for 3 years. It has 450,000 people and is in the top 5 countries in the world of population density. Throw in that it has very high car ownership. Almost every inch is developed and not to nice standards. Where it is a bit rural, hunters will shoot every bird, protected or not that tries to fly over Malta. It is also very dusty. But most important is if you have never lived on an island, is the small size. Lovely friendly people though, but︀ I could not wait to leave.
And if your first trade is eur/btc and after you trade only btc/alts how to calculate all this trades? It sounds strange such approach. Did you ask ANAF? Do you have any official reply from them? I also have micro SRL in Romania and i invested profit from SRL in crypto, but i am not aware of such taxation.
I have a reply from 2 lawyers. And that's what I suspected given that the company is taxed on revenue, not profit. The ANAF didn't offer any useful reply ever.
You calculate it the same way as if you were left︀ with BTC only in your account at the end of the year. You take the︁ current value in RON. Except, you have to do this for every trade each month.︂
You calculate it the same way as if you were left︀ with BTC only in your account at the end of the year. You take the︁ current value in RON. Except, you have to do this for every trade each month.︂
Initially, I went with the idea of English speaking, lots of sunshine, med life, zero tax for non-doms etc. This was 2008 and a got a bargain on a house with a large swimming pool. The first year was all right, every town has its own saint and own festa. This festa consists of loud explosions, waking you up at 8 AM to let the rest of the island know there is a party in your town. For one week you wake up with world war 2 type explosions at your doorstep. The parties are fun︀ with local food and activities cumulating in a firework show on the weekend. Maltese love︁ fireworks and these shows are amazing. However, all these shows are done by volunteers and︂ they do not have the strictest safety rules. So expect once every 3 to 4︃ years a fireworks factory to explode, you will hear this island-wide (world war 3 explosion).︄ They promise safety rules, but eventually, nothing will be done. But all these parties are︅ actually all the same, same food, same sort of fireworks etc. Good for one year︆ when I visited 12, but for the next year hmmmmm.
Eventually, you will feel the︇ size of the island, and how crammed it is. The roads are potholed and bad,︈ they get fixed when the pope arrives and only the roads his car drives on.︉ Locals are bored too and want to show off their driving skills by driving fast︊ and dangerous. Rich Libyans that fled their country have nothing better to do than race︋ their loud cars around town.
Real estate development is done by putting up as quick︌ as possible the skeleton of the building. If you want your own apartment, you will︍ have to put the walls in and do the interior. What this has done is︎ that you find these skeleton buildings everywhere on the islands.
Next you have the refugees️ that
As you have 450,000 people on a tiny rock, you run out of resources quick. Where to put the rubbish, how to develop sustainability, how to have enough drinking water and water for pools etc. You will be surprised about the number of illegal boreholes pumping out water, this is how my pool was filled.
When you want some quiet time and go around the bit of nature that is left you will be surrounded by hunters trying to kill every bird that flies over. This goes on for 6 months of the year. If you say something, you become the target.
oh, when︀ it comes to schooling, local schools are very religious, this is a 95% Catholic island.︁ So your kids will get brainwashed. The only international school as a long drive and︂ with traffic bad you will feel those school runs.
I feel for the Maltese they︃ are so friendly and they have to live with all this sh!t.
Eventually, you will feel the︇ size of the island, and how crammed it is. The roads are potholed and bad,︈ they get fixed when the pope arrives and only the roads his car drives on.︉ Locals are bored too and want to show off their driving skills by driving fast︊ and dangerous. Rich Libyans that fled their country have nothing better to do than race︋ their loud cars around town.
Real estate development is done by putting up as quick︌ as possible the skeleton of the building. If you want your own apartment, you will︍ have to put the walls in and do the interior. What this has done is︎ that you find these skeleton buildings everywhere on the islands.
Next you have the refugees️ that
As you have 450,000 people on a tiny rock, you run out of resources quick. Where to put the rubbish, how to develop sustainability, how to have enough drinking water and water for pools etc. You will be surprised about the number of illegal boreholes pumping out water, this is how my pool was filled.
When you want some quiet time and go around the bit of nature that is left you will be surrounded by hunters trying to kill every bird that flies over. This goes on for 6 months of the year. If you say something, you become the target.
oh, when︀ it comes to schooling, local schools are very religious, this is a 95% Catholic island.︁ So your kids will get brainwashed. The only international school as a long drive and︂ with traffic bad you will feel those school runs.
I feel for the Maltese they︃ are so friendly and they have to live with all this sh!t.
Romania v. Hungary.
Divide the 3% tax (ROM) by 11% tax (HUN) = " .2727 " (1-.2727=.7273) This is the break even point in business costs = 72.73% of Revenue.
So, up to 73% business costs; Romania is the better option, over 73% then Hungary is the better option.
Of course: 'Ceteris Paribus': (assume all other costs are the same) JUST on CT.
[OF COURSE...need to do a deep dive on ALL other aspects: e.g. salary/social/office/admin/legal/banking/forex/visa/living etc.... ]
Just looking at CT not dividends as its not clear where the dividends are going.
Basically... if you are a dickhead, and have a large percentage of Alien DNA...move to Malta...you're︎ welcome, not for me, I left the only Island I lived on 30 years ago.️ Never been so contented since. Maltese Falcon...is a classic movie though...Bogart and Lorre.
Divide the 3% tax (ROM) by 11% tax (HUN) = " .2727 " (1-.2727=.7273) This is the break even point in business costs = 72.73% of Revenue.
So, up to 73% business costs; Romania is the better option, over 73% then Hungary is the better option.
Of course: 'Ceteris Paribus': (assume all other costs are the same) JUST on CT.
[OF COURSE...need to do a deep dive on ALL other aspects: e.g. salary/social/office/admin/legal/banking/forex/visa/living etc.... ]
Just looking at CT not dividends as its not clear where the dividends are going.
Basically... if you are a dickhead, and have a large percentage of Alien DNA...move to Malta...you're︎ welcome, not for me, I left the only Island I lived on 30 years ago.️ Never been so contented since. Maltese Falcon...is a classic movie though...Bogart and Lorre.
I've made it to Hungary. So far my impression is not the best, my new landlord has tried to rip me off right in the beginning. Wouldn't even wait for the end of the lease to try to steal the deposit like everywhere else ... just right from the get go tried to squeeze out fraudulently as much money as possible. What kind of a culture is that ...
I hope that is a one off. Deposit stealing happens almost in every country, but when you want to leave. But ripping you of as you just arrived is new to me. Hope it all works out.
I'm suprised that @CyprusLaw and @CyprusLawyer101 didn't comment on this, both may know how this could work ?
I seem to have missed this, so thanks for pointing out 🙂
To begin with it would be better to seek advise from a Romanian advisor for this.
Will the Romanian company be the shareholder of the Cyprus company and therefore the RomanianCo will receive dividends from the CyprusCo? If this is the case it is likely that the Parent-Subsidiary Directive (2011/96) will kick in, exempting such payment from withholding on dividend payments.
To begin with it would be better to seek advise from a Romanian advisor for this.
Will the Romanian company be the shareholder of the Cyprus company and therefore the RomanianCo will receive dividends from the CyprusCo? If this is the case it is likely that the Parent-Subsidiary Directive (2011/96) will kick in, exempting such payment from withholding on dividend payments.
No it does not, I've already described it somewhere in the forum. I got a reply from a Romanian lawyer who confirmed me what I suspected - the exemption only applies to companies taxed on profit. Since a micro-company is taxed on revenue, the exemption is not applicable and has to pay 5% no matter what.
The 5% tax in Romania would normally apply. This is in essense a witholding tax and it could be reduced or eliminated through an applicable double tax treaty between Romania and Cyprus. If i am not mistaken, the treaty rate in place is not 0%. Muat be either 5 or 10%.
If no treaty relief can be obtained you could resort to the Parent Subsidiary Directive and see whether you could satisfy the requirements there. Of course, local practice and requirements are important to be assessed as well and that is where an additional opinion on the ground would be required.
If no treaty relief can be obtained you could resort to the Parent Subsidiary Directive and see whether you could satisfy the requirements there. Of course, local practice and requirements are important to be assessed as well and that is where an additional opinion on the ground would be required.
hi All
i see that all of you suggest that micro company is subject to wht 5% on dividends distributed to its mother but according to a recent ordinance and an emendament included it seems that the EU directive should be applicable also to micro-companies (they extended the EU directive implementation to companies using a taxation different from CIT).
So the structure CY+RO micro company 1% should be fine. Glad to hear the opinion of people more expert than me about RO (i am just reading online).
What instead i believe should be considered is the holding period, which is 1 year in RO, differently from CY where it is immediate.
https://www.orbitax.com/news/archive.php/Romania-Publishes-Ordinance-fo-47532
i see that all of you suggest that micro company is subject to wht 5% on dividends distributed to its mother but according to a recent ordinance and an emendament included it seems that the EU directive should be applicable also to micro-companies (they extended the EU directive implementation to companies using a taxation different from CIT).
So the structure CY+RO micro company 1% should be fine. Glad to hear the opinion of people more expert than me about RO (i am just reading online).
What instead i believe should be considered is the holding period, which is 1 year in RO, differently from CY where it is immediate.
https://www.orbitax.com/news/archive.php/Romania-Publishes-Ordinance-fo-47532
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