Setup low-tax EU company in Cyprus or Bulgaria

RnK

New Member
Oct 2, 2017
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I'm checking the "normal" forums for many months and found some very valuable information, and I hope the mentor group can help me out finding the perfect solution.

I'm based in Belgium (EU) working as a freelance internet marketing consultant for some EU based companies, turnover €100K+. As I pay a huge amount of taxes (+50%) I want to setup a EU based company with VAT number in a low-tax country, and regarding tax rates I guess Cyprus (12.5%) or Bulgaria (10%) are one of the best choices to make (correct me if I am wrong).

I'm planning to move to Portugal within 1-2 years, where I hope to take advantage of the NHR (Non-habitual Resident) status, which means I will be exempt from personal income tax for 10 years. As long as I stay in Belgium I will not need any funds from my new company, only after I close my Belgian company and move to Portugal.


A few questions with the above situation in mind:

1) To prevent problems in my current or future (Portugal) resident country regarding "Control and Effective Management" I probably need a local director (nominee), and/or shareholder? If I become an employee of my new company when I start living in Portugal this structure will not cause any problems?

2) With the CRS/AEOI up and running since last month how to prevent problems with my local tax office? Obviously I don't want them to know I have a company in Bulgaria or Cyprus, but as I will probably be the "Ultimate Beneficial Owner" how to prevent them tracking me? In case you suggest the Seychelles-Cyprus/Bulgaria construction please explain, as Seychelles is also on the CRS list?

3) Which is better for company setup, Bulgaria or Cyprus? What are the advantages/disadvantages when you compare them both, the tax difference isn't that much.

4) What are the average yearly maintenance and accounting fees for a company in Cyprus? Accounting fees in Bulgaria are quite high, as every document (incoming/outgoing invoices) need to be translated (I received a quote from a reputable company, *accounting only* for 50 incoming/outgoing invoices was €400 / month).


I'm very curious to your replies, thanks a LOT for your help!
 
RnK said:
I guess Cyprus (12.5%) or Bulgaria (10%) are one of the best choices to make (correct me if I am wrong).
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True, but you need to setup a real office with some sort of "real staff" in order to convience your local tax office that the company is controlled and managed in Cyprus (or Bulgaria) also a utility bill would be some good evidence.
RnK said:
If I become an employee of my new company when I start living in Portugal this structure will not cause any problems?
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Not if you setup the company as above mentioned, you will be employed as any other person. Just make sure nothing lead to you!
RnK said:
2) With the CRS/AEOI up and running since last month how to prevent problems with my local tax office? Obviously I don't want them to know I have a company in Bulgaria or Cyprus, but as I will probably be the "Ultimate Beneficial Owner" how to prevent them tracking me? In case you suggest the Seychelles-Cyprus/Bulgaria construction please explain, as Seychelles is also on the CRS list?
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Only way around it today is either a large and complicated Trust / Trustee structure or Foundation, managed accounts through a Trust or setting something up through DARKS or a middleman!

On the other hand, I would wait to open any bank account until you moved to Portugal and know that you can apply for the NHR and don't get complication through such a setup.

I have no knowledge about Bulgaria other than it's not the favorit jurisdiction large investors move to.

Cyprus is usually 3500 in total for accounting and tax report / financial report. up to 80 invoice per year.
 
Can this Work with Cyprus as primary holding Company or also with Bulgarian Company?
 

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