Bypass CFC , POA well if ......

[Loisir]

Hello All,

As you can see on my previous thread "Fr / Ger / Uk / Africa -> complexe Set-up " i have a very complex situation.
Little reminder. FRA citizen, Living in GER, Dual nationality with North African country
Online business with clients mainly focused on France

Maybe i finally found a way to proceed. i Went trough CFC , AEOI, CRS will make a thread about it.

All Theses solutions will be run only with payment processors and EMI and no salary will be Funded on my account.
After the business growth then think about a more complex set-up with maybe UAE or so. Have a agent there they went out EU black list last year but re-enter this year because they don't disclose account for resident even if they are EU national. As soon you still have a Residence visa and visit the country each 6 Months its good.

Solution 1 :
Maybe a Us LLC New Mexico with my North African Passport so they maybe report only to the North African country. US LLC own the website then Uk Ltd with nominee director and shareholder use the website. A huge amount of the turnover will go to the Us LLC as a licence. Show some clients in Uk and rent small shared office 50£/Month in Bradford.
then profit to account in Morocco (They have signed MCAA and have bilateral tax plan with France. However under OCDE it say that the automatic exchange will be effective in Sept 2021).

Solution 2 :
UK Ltd with Nominee director will act as he is in control of the company and we will try to focus also on client in UK to show some substance with the Shared office in Bradford. when you apply for a nominee director you get 2 docs one of them (you have to add money for it ) is POA. But then if you don't purchase the POA , you can state that the nominee director act as a control management guy. Then i will be a Shareholders only , no CFC rule will apply. If i sign the POA does the clients and the office will be enough to stay taxed in UK?

Solution 3:
UK Ltd with Nominee director as a Friend who come from north Africa too. he will act he manage the company and as I'm simply Shareholders however regarding CFC ( if His country have one ) he will be liable to his country. (Algeria) but no worries about collecting tax there. Focus also on Uk clients to show substance and maybe office in Bradford


I personally prefer the 2nd Solution what you guys think about. the fact is that i live in Germany but just for One year , so i can print the idea of Paying 32% Tax because of an obligation to be there 1 year for work.

Regards,

 

[MarkusM]

Have a agent there they went out EU black list last year but re-enter this year because they don't disclose account for resident even if they are EU national. As soon you still have a Residence visa and visit the country each 6 Months its good.

What are you saying there? When EU blacklist someone, that one is the country itself, not the agent. The UAE was removed from the blacklist!

 

[Loisir]

Hello alex ,

thank you for your return. However on the list issued the 5Dec 2017 UAE was on black list . They was removed the 23 January 2018 then they joined again the black list the 12 March 2019 after was a last remove occurred the 10 October 2019. you can check on eu.europa.eu

Basically they will maybe be re added on black list as soon any National get residency they , for the moment don’t give informations to Eu countries .
When a countries move from Black list to Grey list it means the country engage itself to give some informations about foreigner holding account under their juridiction. Theirs resident are not for the moment concerned.
Regards,

if you have any opinion on the solutions of the thread it will be with pleasure

 

[nomad999]

if you bring the profit to a bank in Morocco, what information do the bank have on you ? a morocco address and tax id ? this is something you need pay close attention to.

 

[Loisir]

North African Nationality and for the adress we can make other one. Eithers way , even with the EU adress Account have huge chances to be reported Sept 2021 But by this date i will not be there anymore

if you guys have any input please it will be with pleasure

 

[JohnLocke]

Thank you for the information, it's very useful it seems but need some modification as it looks.

 

[nomad999]

North African Nationality and for the adress we can make other one. Eithers way , even with the EU adress Account have huge chances to be reported Sept 2021 But by this date i will not be there anymore

if you guys have any input please it will be with pleasure

hmm what ?

bank will report based on the information you give them.
if on your morocco bank you are registered with your morocco id, a morocco address and a morocco tax id, they won't report to anyone else than morocco. they have no reason to report to any other country.
bank don't just report out of nowhere, they only do what they are required to do by law.

btw the nationality of your passport or id doesn't matter much unless you are US citizen, it's the country of residence registered with the bank that matter.
again, this is important you, might very well solve all your problem here if you understand that correctly.

 

[Loisir]

I will make a thread regarding this soon with all the research regarding AEOI,CRs etc... @Admin

@nomad999 Im Afraid off on my North African Id it show my French Adress As residence.
If you have please an advice regarding to solution 1,2,3. You can adapt them as you want to give the better outcome.

If someone else have also opinion. thank you

 

[nomad999]

@nomad999 Im Afraid off on my North African Id it show my French Adress As residence.

Ok but still, the address on your ID is not what matter, what matter is the address of residence you declare to your bank.
You could try to declare a local address with a utility bill or whatever proof of address they require, basically you are pretending to be a resident of morocco which might be doable or not I don't know exactly but my little finger tells me there is something possible there.
What matter is the address that shows up on a bank statement under your name, so if you can change that you are good and they won't declare to any other country. unless, of course, if that country is actively looking after you and request information, which is another matter.

I have a European passport with an address from a top 5 EU country and yet the financial institutions I registere at I give them my address in Asia where I am a resident.

 

[Loisir]

@nomad999 thank you will do it to extract profit from the company. Regarding the solution 1,2,3

Which type of setup you prefer. I usually would like to go with setup 2 but dont know about the question expressed there ?

 

[nomad999]

sorry a bit too complicated setup for me, I don't do online business so I can't say really.
I would be careful with nominee director if I were you ...

 

[MarkusM]

However on the list issued the 5Dec 2017 UAE was on black list . They was removed the 23 January 2018 then they joined again the black list the 12 March 2019 after was a last remove occurred the 10 October 2019. you can check on eu.europa.eu

Basically they will maybe be re added on black list as soon any National get residency

What are you saying there? Dubai is full of expats from all over the world! If the things were as you said, UAE would be put on blacklist several times/ day .

Think before you speak!

 

[Loisir]

@Alexm
before being arrogant please take a look https://ec.europa.eu/taxation_customs/sites/taxation/files/eu_list_update_18_02_2020_en.pdf

After that i told you that UAE was severally added then delete from the EU Black list and they will be re-added.

The fact is that a lot of "Expats" i'm not talking about the real one who work there but the one you go there only to get the ID. UAE dont share information with EU for this purpose if you visit the countries 2 times a year.

Regard