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Best setup with Portuguese NHR + LLC single + EU companies

tradeall

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Mar 31, 2024
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Hello guys. I have searched a lot in the forum but I didn't find anything conclusive in those posts.
After doing some investment in setting up companies in USA (New Mexico), Estonia and Cyprus I want to be able to be covered if I have to reply to tax authorities if I am required.

I am currently Portuguese tax resident under the NHR regime, and I own 100% of the shares in the Estonian company and 100% of the shares in the Cypriot company. In Cyprus, I have a nominal director and secretary.
Additionally, I have a single-member LLC in the United States (New Mexico)

To demonstrate my income in Portugal, I was suggested by a tax consultant that I can bill around €2,000 per month as a Portuguese freelancer to the Cypriot company and pay the 20% flat fee (plus social security, 100% exempt the first year), then take the rest as dividends.

My question is whether it would be more advantageous to set up a company in Portugal, where I could either bill the Portuguese company or receive a salary from it, so that I could invoice my Spanish clients from the Portuguese company. I could also turn one of my existing companies (LLC, Estonian, or Cypriot) into the holding company of the Portuguese entity, so I wouldn't have to pay taxes on dividends in Portugal as I would pass them to the holding.

With this current setup, what would be the most advantageous configuration to ensure peace of mind and that no tax authority could give me trouble?
The reason why I would plan to open a company in Portugal is that I can demonstrate better that I live in portugal rather than get dividends from Cyprus but I don't want to pay dividends from portugal because I think that although I have the NHR I have to pay dividends from my hypotetical portuguese company.

Any ideas or suggestions? Thanks to all that take the time to read the post
 
With this current setup, what would be the most advantageous configuration to ensure peace of mind and that no tax authority could give me trouble?
Best is to ask your local tax advisor or certified accountant. You are already setup and have registered several companies you know what you are doing.

Now you just spend a few thousands on a very good tax consultant i.e. tax lawyer or accountant or both and you are good to focus on your business.