Switzerland vs Singapore vs Hong Kong Tax Set up for Foreign income?

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banafinfodafuggiano

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Jun 18, 2020
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Is there any set up that I can create (as a EU citizen living in Asia) to launch a company in any of these following counries
and pay ZERO corporate Tax since 100% of my income is sourced from outside these countries?


- Switzerland
- Singapore
- Czechia
- Austria


Or do all of these countries tax foreign sourced corporate income? (director non resident)
 
It's doable in Singapore, if you have no presence there, and if you don't move‌ the money to Singapore or use the money for payments/transactions in Singapore.
 
If you have no presence then I assume you don’t have tax residency‍ there?

What countries could you then take tax residency to pay no additional taxes?
 
A place without taxes or which doesn't enforce its tax laws (in‍ certain cases).

Panama, Costa Rica, Dominican Republic, Malta, Cyprus, Bahrain, Bahamas, Caymans, Bermuda, and so⁠ on.
 
0% Foreign income tax on corporate level?

What about costs to set up‍ and running? are they are high as Dubai and also require constant auditing?
 
Singapore taxes on‌ source and remittance. If you don't do business in Singapore and don't remit funds to‍ Singapore, you'd fall out of scope for corporate income tax.

If we're only considering company formation and maintenance costs, the difference⁣ is quite small. Singapore is a bit more expensive.
 
What exactly does this mean?‌
Not having a bank account in Singapore?
Don't use the money to buy anything in‍ Singapore?
 
If your company is tax resident of some jurisdiction with‍ territorial tax system it always leaves a question where the income is sourced and some⁠ day you might have to prove it somehow.

This is why Singapore is probably the⁤ best jurisdiction for such approach, as it doesn't tax or issue tax residence certificate based⁣ on incorporating a company there, so you could get away with the company not being⁢ tax resident anywhere, and you can be the company's shareholder and employee/representative. Probably best is︀ not to be the sole director though depending on your exposures.
Its worth noting that︁ Singapore is not a "banana republic" but a reputable financial hub. On top of that︂ its probably one of the best structure for high-risk activities (even arms dealers/defence industry uses︃ it a lot, and they don't have too many great alternative options).

Under Singapore tax︄ law, the tax residency of a company is determined by where the business is controlled︅ and managed, so you could present to Singapore tax officials that board meetings are held︆ in e.g., Bahrain (0% tax country), or in limited cases (Estonia, see below).

However you︇ probably want to have a permanent establishment registered somewhere so you could have some substance︈ for compliance purposes as it would be great to have some fixed place where the︉ company's operations are at least partly performed, and to have a tax number somewhere (and︊ in result better access to banking).
For this purpose I can recommend getting a substance︋ package from Estonia (e.g., rent office and hire one Estonian resident professional director or employee︌ part-time in Estonia). Estonia is a great choice for the following reasons:
1) Estonian legislation︍ doesn't allow claiming foreign companies as tax resident in Estonia. It can only tax its︎ PE.
This means Estonia can only tax the profits attributable to the PE, which can️ as well be 0.
2) even if profits are attributable to the PE, then profits‌ of the PE are not taxed before the profits/assets are taken out from the PE,‍ and not if the assets are returned to the PE in one year
3) you⁠ are not obligated to register a branch office, like in many jurisdictions (but can still⁤ register for tax and register a PE) and do not need to follow local accounting⁣ rules for the PE
4) it helps to access Estonian and other EU financial institutions⁢ since you would have established EU presence this way
5) it is even possible to︀ structure it so to have the PE registered, but it will not even be considered︁ a PE under the tax treaty, so the PE is not taxable either.

Depending on︂ your personal tax residence or if you are nomadic it can be a great structure.︃ Happy to help with the setup.
 
Correct. Not wired to‌ Singapore, not made available in Singapore, and not spent in Singapore.

Once the money has‍ passed through the company and if you distribute dividends to yourself, it's not likely the⁠ IRAS would after you if you spend the money personally in Singapore. It's not that⁤ extreme.
 
Next question then:

Which countries⁤ are amicable to opening a bank account for a Singapore company? 🙄
 
Doesn't work like that. It's about what the company does, where it's‍ based, who the owners/directors, et cetera are.

A Singapore company selling ebooks with owners/directors resident⁠ in Malaysia is different form a Singapore company selling toxic waste materials with owners/directors based⁤ in Ivory Coast.
 
I can talk a bit about this. If you have no operation in Singapore.⁠ Usually it costs max a couple of thousands USD per year to do audit and⁤ hire a local nominee director
 
Let me narrow it down then:

  1. Company A only purchases⁤ robotics, IT & household products (***see attached video; sound removed) in China and resells them⁣ to wholesalers around the world.
  2. The company director (B) lives in Monaco. (Not a US⁢ citizen or Eritrean citizen)
  3. Turnover from Company A is US$50M per year.
  4. Gross profit is︀ $5M.

Which "reliable" countries or banks (except banks in Singapore) are amicable to opening an︁ account for Company A?

*** Video of household goods.
 
When it comes to reliability a⁢ lot depends on the context.
I assume you forgot to mention that its a one-person︀ company, which can make it somewhat more difficult to open an account unless you are︁ willing to establish some minimum level of economic substance in the jurisdiction of the bank/financial︂ institution.
From my experience, it seems to me that there tend to be specialized service︃ providers for dealing with china.
In EU you have a few EMI-s, even banks that︄ are focusing on that niche. I also now some corporate services providers that focus 99%︅ to chinese clients (e.g., in UAE).
 
Title of the thread is confusing and misleading. This is a thread about Singapore and‌ not Switzerland!
 
It seems like Singapore is the best option hence we are talking about that now‌ (f**k Switzerland lol).

So, which banks (except EMIs) can be potentially used to open a‍ corporate account for the Singaporean company?

Being a non Singapore resident, it seems like it's⁠ going to be tough.

my background is:

EU/CA citizen
ecommerce: selling toys for children., completely⁤ white hat. With track history over 7 figures in sales on my Canadian company.
 
Why does it matter if all you're⁣ doing is white hat sales and are a resident of a low tax/zero tax country⁢ while operating a Singapore company from remote?

I'm looking at Singapore because it seems like︀ Taxes can be reduced to zero in my business case and it also is compatible︁ with several payment gateways (way more than the UAE)...
 
I was referring to opening a bank account in⁣ Switzerland for your Singapore entity highlighting that Switzerland might still be useful.
 
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