Recent content by qwerty84

You don't have tax treaty protection, but that does not mean that other EU member states will just tax you. You will need to satisfy the criteria for tax residency under their domestic laws, which is usually either x number of days physically present or having your economic center of life in...

Are you serious? OECD is the leading authority for international tax rules and all of Cyprus' tax treaties are modelled after the OECD model and will be interpreted by the tax authorities in line with their guidance. Yeah, nothing to see. By the way, I'm a certified tax advisor.

You could not "simply" down that. You should look into the OECD meaning of "place of effective management". It certainly does NOT include nominee services....

I'll explain a little better. You are I'll explain in some more detail. You may be a tax resident under domestic tax laws, but not a tax resident for purposes of the application of the tax treaty because you are only subject to tax from local sources. For example, in the UK - Cyprus tax treaty...

The "beckham law" (non-resident tax treatment for impatriates) is article 93, which, after the startup law, is worded as follows (Eng translation): 1. Individuals who acquire their tax residence in Spain as a result of their displacement to Spanish territory may choose to pay the Income Tax of...

I actually have read the draft law... see attached. It ONLY applies to employees, not self employed. The publications are misleading.

I read into the law, and although Spain is presenting it as being a tax benefit for digital nomad "entrepreneurs", in line with the current rules of the Beckham Law you (i) need to be employed and (ii) cannot hold a share interest larger than 25% in the employing company. In other words...

Your main issues will be (i) non-doms are not considered tax residents of Cyprus under most OECD modelled tax treaties, so other countries can claim tax residency (including Spain, based on having your economic center there) and you wont be protected by a treaty and (ii) place of effective...

Portugal could work with a foreign EU trading company, as long as you're nomading and not staying in Portugal for too long? The trading company is not a CFC (because its in the EU and its an active company) and its place of effective management should not be in Portugal.

Does PT CFC legislation even apply to individuals? That's broader than ATAD1