Tax residency for protection

[piratechain]

I have someone who is the single member of my manager managed US LLC and the director of my Seychelles IBC.

This person is someone close to me and a perpetual traveller meaning no residency somewhere, no flat rented.

I would like to get for this person a tax residency for compliance reasons and protection, so that a tax certificate can be issued easily and is recognized by a european country.

The country should be completly tax free or under a territorial tax system and no CFC Rules in place.

I would prefer a country which is closer to europe.

I guess it helps for compliance reasons if the country is not blacklisted by EU? (not sure here, home country is in europe and the place where the person spends the time during the year is currently Cyprus, Germany, Ukraine and some other european countries every country not more then 2 months in one piece and not more then 183 days per country).

Preferebally there is no need to spend time in the country where the tax residency is (or as little time as possible, 183 days is out of the question)

In my research countries that make sense with no tax are:

- Bermuda
- UAE
- Cayman
- BVI
- Bahamas

or with a territorial tax:

- Angola
- Botswana
- Costa Rica
- French Polynesia
- Guatemala
- Dom Rep
- Hong-Kong
- Jordan
- Macau
- Malaysia
- Namibia
- Nicaragua
- Paraguay
- Panama
- Seychelles
- Singapur
- Taiwan
- Philippines
- Uruguay

 

[Liam13]

Looking at your list, getting residencies in some of these countries is not cheap (singapore, hk) and might require the 183 days

 

[jon1234]

Paraguay is fairly cheap and only requires occasional visits

 

[daniels27]

With all due respect, in most cases any certificate is essentially useles. Hong Kong for example already warns applicants for the certificate that it by no means guarantees anything as the other party can do any check to determine the real tax residency. There are only very few limited cases where such a certificate makes any sense, in most cases it is useless.

And just to comment on your list, if you manage a foreign company from Hong Kong, you need to register that company in Hong Kong and pay tax in Hong Kong. Many others of your list are pretty much the same. If you go the route of getting such certificate and spend time there, you open doors to Hong Kong etc. to tax the hell out of you. BVI is taxfree? You know, they have around 10% social security contributions on your salary (you will pay about 20k USD per year). I do not know why this place always makes it onto such lists, but it does not really belong there. UAE also has tax, etc. etc.

Also, you may want to check which country you are talking about in Europe as most of the time any such certificate is essentially absolutely toilet paper if not connected to a double taxation treaty.

I would rather not get it but ensure your dude does not spend more than 30 days in Switzerland etc. as you will be taxed there as well otherwise. Just document your buddies travels will most likely help more with less troubles.