Recent content by Don

You need to build substance for these structures, else it will not work. Cyprus is a great jurisdiction in the EU for a holding company.

It could indeed possibly pass the initial scrutiny. I can imagine it's theoretically possible to create a PE abroad that is not taxable. As an example, one could argue that the company has a PE in Estonia, and it is not taxed because the profits have not been withheld from the Estonian PE...

It seems you are referring to the provision which says the following: "For income of the natural person that is neither derived through their foreign permanent establishment nor through their permanent representative operating in a foreign state, it shall be assumed for the application of this...

Do you really want to live most of the year in Dubai for real? You mention wanting to move abroad but are you moving to Dubai? With 12k euros per year, I have doubts you will afford the lifestyle you expect in Dubai. Only the corporate and residence setup there can cost you more than that. Also...

Looks like a good time to leave. You can probably avoid French exit tax by staying under the thresholds and leaving before company grows too big.

Could also do UK company treaty resident in UAE. Best of both worlds?

I can confirm its not the case. Perhaps it used to be.

Fiscal unit can get direct 5% Regular holding setup can apply for refund (effective tax is still 5%)

You should generally outsource management of the holding to avoid issues like the income to be treated Maltese source and subject to 35% CIT

There was a pretty substantial correction already. Any further comments on your thought processes? In the meantime Trump established a crypto reserve...

Hiring remote team members doesn't require any registration, nor is it taxable. EU companies can do business anywhere across the EU without registering a branch or subsidiary. Some countries like Estonia also allow foreign entities to do business locally without registering a branch or...

Deemed PoEM is very important. HK, for instance, is famous for deeming foreign income as local. I've heard of cases where even foreign income from hotels abroad was retrospectively taxed in HK, as the local director was not able to prove that the director was not involved in generating that...

Your thought experiment highlights a potential loophole where a company could avoid corporate taxation due to mismatched residency rules and lax PE enforcement. Estonia wouldn’t automatically claim 100% of the profits unless a robust PE exists, and a nomadic setup with a remote team in Thailand...

Well said. I feel the same. I guess their ability is to serve certain customers that EMI-s wont touch.

My dear sir, there is a distinct pleasure in theorizing, as it allows the mind to explore endless possibilities and construct elaborate frameworks of thought. What if the original poster stumbled upon a cold cryptocurrency wallet, complete with keys, at a humble garage sale, only to discover it...