Estonia Company + Cyprus PE + CY Residency

#22
@Don To be sure to understand, there is no way to avoid the 20% distribution taxes with a CY holding considering a simple structure like below, right?

CY Holding - Estonian Trading (non-resident)
CY Residency (considering a non challenged PE in CY for EE company of course..).
 
#23
Yes you cant avoid this 20% like this as its a CIT not withholding tax.

Its rather opposite:
With Estonian residence + estonian holding and cyprus branch or subsidiary you avoid 2.65% tax otherwise payable by Cyprus resident persons when they receive dividends
 
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