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The.. OffShore of 2020!

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Indeed, a number of EU states are quite aggressive in regards to the use of overseas‍ invoicing companies.

You can still pay all personal taxes in Malta on the income you⁠ earn from your projects in the Netherlands or Germany, but this requires a social security⁤ (A1, formerly e101) certificate from Malta. And you only get this A1 certificate from Malta⁣ if you have a track record of making social security contributions in Malta.

There are⁢ rumors of Bulgaria handing out those A1 certificates without proper due diligence. Primarily abused by︀ firms who appoint temporary construction workers across the EU. For the issuing state, every A1︁ certificate they issue entitles them to tax revenue, even if not much, it's better than︂ nothing. If you want to reduce tax burden, look around for easy opportunities to fetch︃ that A1 certificate from a low tax member state. With A1 certificate, you can work︄ for up to 2 years in another EU country while paying all personal taxes in︅ your "home country".
 
That's Great!! Home country will be my citizenship country or the Tax residence country?? Because‌ if is the first (citizen) leave it.. its very high 🙂.. if its the Tax‍ residence country, how i can work in another country and keep the 183 days in⁠ the Tax R country then? I will be thrown out.
 
I don't think you fully understood. Nobody will "throw you out".

If you live in⁣ Malta and pay social security taxes there, you can apply for what is called an⁢ A1 certificate for your temporary assignments abroad. They will be more than happy to give︀ you one. In the EU, an A1 social security certificate is essentially an equivalent to︁ a tax residency certificate. During the validity period of your A1 certificate, your tax residency︂ in Malta is recognized all across the EU, even if you spend 0 days in︃ Malta.

This document shows a degree of commitment to one member state. If you tell︄ the Netherlands or Germany that your intention is to permanently relocate there, they will ask︅ for local taxes from the first day you arrive. With A1, Malta will accept you︆ back and consider you a resident, don't worry about it 🙂
 
Understand.. Great,., the questions come now to;..

If you are CITIZEN of Italy, and TAX‌ resident & resident of MALTA, and you move to work to ITALY (back to your‍ citizen country) will this be working ? 🙂

Good question eh ? 🙂
 
A Good question because you know I can't possibly answer this one with a⁤ degree of certainty 😉

Temporary assignments abroad are covered by EU directives, and by law, it⁣ would be completely acceptable to tip your nose back in Italy, even work there for⁢ a while. However, under such a scenario, Italy could rightfully consider it an intentional abuse.︀

I'll give you two edges of the argument.

1) You're absolutely fine if you can︁ prove (to Italy) that you have worked for other clients in other countries, at least︂ 2 years have passed since you left, and you can show at least 2 income︃ tax returns from Malta.
2) You're certainly in trouble if you cannot prove that you︄ have worked for other clients in other countries, furthermore, you come back as a Maltese︅ working for your previous Italian employer; very little time has passed since you left, and︆ you have not yet paid any taxes in Malta.
 
But difficult to work back with A1 to same country of citizen to avoid the‌ tax of them (Italy)...
Many thanks @xzars

So getting back in topic, is it ok‍ with the Marsall company?
 
LOL no awe¤""%awe¤""%

With a Marshall Islands company you can wipe a*s these days.

Maybe you can enter into‌ a contract with a non-reputable, irrelevant EU company in an irrelevant business sector. If you‍ want to enter a contract with a reputable EU client, or with any client in⁠ a regulated sector where clients pay well, i.e. medicine, insurance or banking, you will hit⁤ a stone wall. Nobody will accept you. Auditors, regulators and tax officials would torture them⁣ even during their sleep. Needless to say, payments and remittances in such a relationship would⁢ be a nightmare.
 
If you want to do business in EU, you should stick with‍ EU options. Alternatively, consider a non-EU country that has DTA agreements with the EU states⁠ where your primary clients are.

Why?

I've used Gibraltar companies for various puroses. Gibraltar is⁤ a full member of EUEA and has quite stringent incorporation criteria. Furthermore, I have a⁣ real office and employees. On numerous cases, I've had to re-arrange my contracts and banking⁢ affairs because of counter-party "de risking". If this can happen with a company registered in︀ EUEA, then what purpose does a company registered in a [zero tax/no reporting/no audit/no incorporation︁ criteria] non-EUEA country serve? A company you described is OK for passive holdings, or perhaps︂ for doing business in central Africa, but it will certainly not work for any service-based︃ hustle in the EU. Bring your expectations lower.
 
Perhaps a small company in an unregulated sector is fine with it. I'm not‍ predicting it will go as so smooth if you want to do a bit of⁠ work for a Maltese bank.

With that said, if you believe there are opportunities for⁤ your Marshall Islands IBC out there, it makes sense to keep it in your pocket.⁣ When you close a contract, sign on behalf of that IBC first. If the client⁢ gets paranoid, offer a cleaner alternative.
 
Alright then, but this opens up a whole new set‍ of issues to consider. You want to make the Marshall islands company 100% owner of⁠ the Malta company, and drain the Maltese company of taxable income you earn in the⁤ EU, correct?

It will cost at least 50K euros annually to make the Marshall Islands⁣ company substantiated to a point where the Maltese tax authorities will give you an advance⁢ ruling and approve some kind of a mildly aggressive tax structure we can put together.︀ The arms-length principle greatly limits what can and can not be done, effectively reducing the︁ tax savings. And then, on personal level, which makes up the majority of burden, you︂ still pay taxes in Malta.

Pointless. I see no worthwhile benefit in that holding +︃ op.co structure unless you want to go wild and not declare your corporate earnings to︄ the Maltese tax authority.

Bye for today, back tomorrow! thu&¤#
 
what is the op.co structure?
No i dont say to make the marshall owns the‌ malta.. Nothing! just invoicing the services through marshall. Customer buys from Malta, and malta buys‍ from Marshall.. thats' it

Thank you so much @xzars
 
@macthaiver as I already told you and xzsar confirmed, using a jurisdiction like Seychelles, Marshall,‌ Belize or whatever would cost you a lot of money to build a structure which‍ is accepted by the EU tax authorities. Because just the registered agent address is not⁠ enough. The tax authorities also know the most offices the online offshore providers sell you,⁤ they have a database for wellknown nominees and office adresses. So they can immediately deny⁣ your "substance appeal". Always remember that the EU members are quite well connected.
So better⁢ choose a country which is not on this list: http://www.europarl.europa.eu/cmsda...621872-Listing-tax-havens-by-the-EU-FINAL.PDF

That's why I recommended the︀ US. They are a G7,G8, G20 and whatever member, they have international power and for︁ diplomatic reasons they won't be seen as offshore jurisdiction by the EU. Most tax authorities︂ I had to deal with never saw big problems in US invoices (if minded the︃ arms-length principle, of course!). They sometimes wanted to see a proof of the service but︄ that's mostly it. If your IT knowledge is very good then you should always be︅ able to show something. Just show them some code, some ESXi setups, dockers, whatever and︆ they are fine. Also mind to show a small history of some emails like "offer-->offer︇ accepted-->delivery-->payment" .
 
What about US LLCs with no US “Nexus”, owned by, say, a Panama company?
Probably no (or very simple) US reporting requirements and no US taxes, only transparent taxation?
 
but what is the cost to keep & maintain such a company?

i mean cost‌ for first year and each other next
 
Hello All,

Just my two cents here, even though I am new to the forum‌ I have been involved in this for a bit, I would say currently the best‍ option would be a Costa Rica company. Still offers bearer shares and it is not⁠ easy, but possible to open a bank account for these companies.
 
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