Sorry for becoming silent, I just haven't proceeded.
The actions are like a two-part rocket, simplified:
1) register and move ownership
2) pay out dividends
So, first to register an entity in EU is pretty straightforward, if you don't know the language/process there are a lot of companies that can help. Then you need some tax advise on moving the ownership and with that any tax owned needs to be resolved and voila, you have your corporate group.
The second part, to actually pay out the dividends can or cannot create implications, when the transaction is between corporations within EU. Are we talking
tax planning (my take on it) or
tax evasion (greedy politicians take on it). What do you need to prove that the holding company is acceptable to received these dividends (I believe
@Martin Everson already touched upon this). Local directors, local employees, a local office, local business engagements, etc, etc.
On top of this you would need to register a
bank account, either through an
EMI or a "regular" bank and things can get complicated if you are not an EU-resident - EU-
citizenship is not enough as of my experience.
And the final step, to actually payout the dividends to you is filled with questions and uncertainties - which made me not move ahead quite yet. You may, or may not, be taxed for this, depending on a lot of circumstances that might not be known once you setup the holding company/structure and make the transaction.
Currently I am looking at incorporating a holding structure with a holding company in either Netherlands,
Estonia or Ireland. And no, it is not going to be tax free and there is a cost of doing this. So you need to know exactly what your break-even amount is so the costs don't exceed the actual net amount received on your bank account, either if it's a one-time occasion or a x years plan.
But reading tax treaties, asking "dumb" questions to lawyers and simulating the dividend flow keeps you pretty occupied to find a good solution
. I am determined not to give away part of my(!) money to greedy politicians that already receive/d so much so the quest continues.
Somebody asked for contact info to the lawyer I have talked to: I would hold my horses till I can really make a recommendation. I talked to some tax lawyers over the years, engaged with some, and as most of you already know, the cost/value is not always that favorable...as you would expect (more favorable to them, I would say).
So, to conclude, there are a lot things that you need to be certain of and you can only trust yourself, so it takes time to understand and of course things (laws) change as well, as I pointed out regarding the new EU-directives in the thread.
