permanent establishment

  1. C

    CFC Rules and loopholes?

    Individual in Country A: The individual is not from US, nor Europe, but from a tier2 or 3 country Country A does not have Controlled Foreign Corporation (CFC) rules or Common Reporting Standard (CRS) requirements but does have Permanent Establishment (PE) rules. Country A does not tax passive...

  2. Understanding the Full Scope of Permanent Establishment Regulations

    Hi, I'm seeking more information on the topic of Permanent Establishment (PE) and its implications. If I am a tax resident of Country A and open an offshore company in Country B, I understand that by law, I must report the ownership of the company in Country B to the authorities in Country A...
  3. R

    Some questions about taxation

    Hi everyone, I have a few questions about a situation I'm encountering and I'm not really sure how to handle this, here is the situation: Let say I have a company in Cyprus, I'm employee of this company and sole director/shareholder, I rent an apartment yearly, I stay in Cyprus 2 months per...
  4. O

    Countries without Permenant establishment laws/rules?

    Could be a stupid question But are there countries without permenant establishment rules where you are able to open offshore company from and actively work on your offshore company business without being forced to pay PIT or CIT due the PE rules, unless money remitted into the country? Thanks

  5. What to Know about CFC Rules & Permanent Establishment – Can You Still Reduce Tax?

    More and more entrepreneurs turn to offshore companies for a wide variety of benefits. To lots of business people, this is all about reducing tax and diversifying assets. To others, it is about minimizing the overall hassle. If you are "lucky" enough to live in a country with lots of...
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    Exploiting double tax treaties to pay yourself a salary without shifting tax residency AND not having to hire employees to create a substance

    If I want to keep tax residency in the current country while having a company in another EU country, the solution is to create an economic substance there. But it seems like it's a problem to hire someone if he/she already has a job, because of limits on work hours. Due to double tax treaties...
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    • Thread
    • cfc double tax treaties permanent establishment poem
    • Replies: 10
    • Forum: Offshore Company

  7. What Is Permanent Establishment?

    When operating an offshore business, you may encounter the term permanent establishment. Simply, permanent establishment (PE) is a way for jurisdictions to tax foreign businesses that operate in their jurisdiction. Before we get into the details, remember that every country has slightly...
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