Estonia taxing undistributed profits in 2026 where people will go to now?

[daniels27]

This I will keep confidential

And are you willing to move all of them to the new jurisdiction?

 

[Nw1]

Many things can work. But an audit for $80? Maybe enlighten us how and where you get this? I mean normally they even charge more for photocopies.

You need to find affordable audit firm that is compliant and have skills similiar to big 4 but still in coming up stage, for example if go with EY their base charge for audit per year is $500 with low transaction volume

 

[Nw1]

And are you willing to move all of them to the new jurisdiction?

No will first test out new jurisdiction and see if it works without a hitch then think about moving that is why doing all this work in advance to before tax changes hit

 

[daniels27]

You need to find affordable audit firm that is compliant and have skills similiar to big 4 but still in coming up stage, for example if go with EY their base charge for audit per year is $500 with low transaction volume

Normally more like $2000, actually.

 

[daniels27]

No will first test out new jurisdiction and see if it works without a hitch then think about moving that is why doing all this work in advance to before tax changes hit

Yes, but one will obviously be more expensive than 1001.

 

[Shadow Atlas]

Haven't we discussed this already in many details here
https://www.offshorecorptalk.com/th...stinations-to-utilize-non-dom-benefits.46922/
https://www.offshorecorptalk.com/threads/0-tax-offshore-company.46506/

You either need to use a US LLC or add a company in front of it. Or you go with Hong Kong or Singapore. All is possible, but costs money depending on your banking needs. For your setup, Hong Kong, Singapore, Guernsey are the usualy suspects. But they all require proper accounting.

If you do not want accounting, you will need to go the US LLC way.

How can you get a US LLC without accounting? You must file tax returns in the US for an LLC...

 

[Nw1]

Yes, but one will obviously be more expensive than 1001.

Any idea about the earlier two options I said how costly ongoing it is going to be and if it fits the bill as per the specs I am looking for?

 

[daniels27]

Any idea about the earlier two options I said how costly ongoing it is going to be and if it fits the bill as per the specs I am looking for?

You mean Armenia and Georgia? They are cheap. But not exactly tax-free in general. Would they be an option for you?

 

[Nw1]

You mean Armenia and Georgia? They are cheap. But not exactly tax-free in general. Would they be an option for you?

Yes those two I think they meet nearly all my requirements right?

 

[daniels27]

Yes those two I think they meet nearly all my requirements right?

Do you want tax-free or not? I think in that counties you would end up paying taxes even if undistributed.

 

[Nw1]

Do you want tax-free or not? I think in that counties you would end up paying taxes even if undistributed.

Those two have foreign income waiver, undistributed earnings did not see them having a rule for taxing though?

 

[daniels27]

Those two have foreign income waiver, undistributed earnings did not see them having a rule for taxing though?

No, they don't have any such waiver.
https://taxsummaries.pwc.com/armenia/corporate/income-determination
https://taxsummaries.pwc.com/georgia/corporate/income-determination

I am sure we can find a way if you have 1001 companies. What is the total annual spend over all ventures?

 

[Nw1]

No, they don't have any such waiver.
https://taxsummaries.pwc.com/armenia/corporate/income-determination
https://taxsummaries.pwc.com/georgia/corporate/income-determination

I am sure we can find a way if you have 1001 companies. What is the total annual spend over all ventures?

Armenia seems not have but Georgia have see; "Under the new CIT system, foreign income is subject to CIT at 15% upon its distribution in the form of dividends." Which means if money stays with company then you don't pay 15%

 

[daniels27]

Armenia seems not have but Georgia have see; "Under the new CIT system, foreign income is subject to CIT at 15% upon its distribution in the form of dividends." Which means if money stays with company then you don't pay 15%

Yes, but what do you want to do with the money? There are plenty of exceptions:
https://www2.deloitte.com/content/d...ments/Tax/dttl-tax-georgiahighlights-2024.pdf

 

[daniels27]

Also, just for my information. Like when you now have 1001 Estonian companies that you need to close. How are you getting the money out in the end? You then pay the 20%?

 

[Sols]

In 2018, Latvia rolled out a new tax regime mirroring Estonia, where undistributed profits are not taxed. It's not quite as cheap as Estonia but usually just a few hundred EUR more. It lacks many of the conveniences of Estonia. But it's worth looking into.

 

[daniels27]

In 2018, Latvia rolled out a new tax regime mirroring Estonia, where undistributed profits are not taxed. It's not quite as cheap as Estonia but usually just a few hundred EUR more. It lacks many of the conveniences of Estonia. But it's worth looking into.

This one:
https://www.njordlaw.com/latvia-introduces-0-tax-rate-reinvested-profit

 

[Despina]

In 2018, Latvia rolled out a new tax regime mirroring Estonia

They will continue to mirror Estonia and start to tax undistributed profits

 

[Nw1]

Yes, but what do you want to do with the money? There are plenty of exceptions:
https://www2.deloitte.com/content/d...ments/Tax/dttl-tax-georgiahighlights-2024.pdf

Their tax code smells decent to me, only question was; An individual also may become a tax resident of Georgia if the individual has high net worth, as defined under the securities market law.
How much is considered high net worth according to them?

 

[Nw1]

Also, just for my information. Like when you now have 1001 Estonian companies that you need to close. How are you getting the money out in the end? You then pay the 20%?

No need to close since you can simply keep the earning in Estonian company since new law would only effect new earnings not old earnings that was undistributed as per my understanding. So only need a new company setup to put the new earnings to