Tax-free residency in Estonia

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Estonia has both PE and CFC legislation present in its tax code⁢ (CFC as of recently), so the above isn't quite right.
 
is not working like that , if you produce income in estonia you are taxble‌ , be carefull with estonians they can be very aggrssive , tax is low in‍ estonia but you should pay them
 
This is correct,‍ but it seems like profit from an Estonian PE is exempt from taxation if said⁠ profit is taxable in the country where the company is tax-resident.

§ 53. Taxation of⁤ permanent establishment of non-resident in Estonia (Income Tax Act)​

 
what about a crypto trader living in portugal that incorporates a crypto︁ trading company in malta for instance. will portugal taxman charge corporate tax from this company︂ on its gains? I understand dividends will not be tax free since cfc rule applies︃ and trading is done from portugal. but curious about the corporate tax part?
 
ok I just read the⁠ above and it answers my question I posted above. Now I am curious if crypto⁤ trading as an individual in Portugal can truly be tax free with someone that made⁣ a significant amount with 50 or so trades.
 
If Portugal does not tax crypto which I doubt they don't then you can be‌ doing fine living there.
 
BTW i asked‍ EMTA about this and they told me that to be tax resident you have to⁠ spend 183 days there. Renting an apartment for the whole year looks like wouldn't do⁤ the trick.
 
The claim "Cryptos are not taxed in Portugal" surfaces from⁠ time to time. In absence of definite, verified information, my guess (based on this article⁤) is that professional traders will have to pay capital gains tax.
 
That doesn't make sense. You⁠ even linked to the article yourself that explicitly states that fulfilling just one of the⁤ criteria is enough. And the first criteria is that "your place of residence is in⁣ Estonia". I believe that Estonia might be a bit less strict about that, meaning that⁢ they will not claim you as a tax resident so easily if you don't spend︀ much time in the country. They would have to prove that your center of interest︁ is in Estonia etc.
But I really cannot imagine that they would say no if︂ you say you want to be considered tax resident in Estonia. After all, it would︃ mean that they can tax your worldwide income. Usually people want to avoid becoming tax︄ resident.
The bigger issue is if you could be considered tax resident somewhere else as︅ well, and then the question would be if there is a tax treaty and which︆ country you have stronger ties to.
And of course the next important thing would be︇ that you can't be controlling the company from Estonia.
 
I wouldn't necessarily read EMTA's response as "183 days is the only way to be‌ tax resident". Did you specifically ask about having access to an apartment but choosing not‍ to use it?
 
So just to make sure⁠ I really understand what you are saying here about NHR scheme of Portugal

(1) I⁤ got dividend paying stocks in my portfolio a withold tax of 15% is taken by⁣ my online broker before these dividends are paid to my account so under NHR I⁢ would pay 0% income/dividend tax in Portugal correct?

(2) I got an apartment in e.g.︀ Netherlands from which I receive income so under NHR I would pay 0% income tax︁ in Portugal correct?

(3) I got Estonian company, I live in Portugal and I manage︂ my online business from Portugal. My Estonian business made a profit X euros I want︃ to distribute it to myself 20% corporate tax is paid in Estonia but I pay︄ 0% dividend tax in Portugal on that income correct?

(4) I got Estonian company, I︅ live in Portugal and I manage my online business from Portugal. I pay myself a︆ salary (instead of dividend) I pay social tax in Estonia but I pay 0% on︇ my salary in Portugal - correct?
 
(1) I think that's correct-
(2) Yes, because you pay tax in the Netherlands︆ (where the property is located). That has nothing to do with NHR though, that is︇ the case with almost all countries.
(3) Wrong.
(4) Wrong.
 
Very solid idea! did you move on with︅ this setup?
I am currently planning my move to romania for 1-2 years to setup︆ my company there with some substance. My plan then was to move to Portugal, but︇ Estonia looks like a very attractive alternative as well!
Just one question: you would still︈ need to pay the dividend tax in Romania if you live in estonia / portugal?︉
 
I did not move on with this setup because I don't want to live in‌ Europe. So I also did not have this checked with a lawyer. It was mostly‍ an idea that I had. The big question here is whether the Estonian tax authorities⁠ will say that your foreign company is managed from Estonia. If they agree that it's⁤ not, this should be fine.
Regarding the Romanian dividend tax, I would think you'd still⁣ have to pay it since it's probably officially a corporate income tax and not a⁢ withholding tax, just like the Estonian corporate income tax which is only paid on profit︀ distributions. You should check with a Romanian accountant/tax lawyer about that.

Is there any additional︁ tax on the personal level in Romania? If not, I would probably consider just sticking︂ with Romania. It's much easier to have everything in the same country.
 
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