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EU citizen, free as a bird, looking for decent tax residency & holding structure.

repeatcaller

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May 5, 2021
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So, I'm kinda losing sight of the forest amidst the trees.

Situation:
- Citizen of Germany
- tax residency & IT business (sole proprietorship) in Austria
- small properties (apartments) in several EU countries
- not married, no kids

Over the past years, my lifestyle has been multi-polar (between EU and Americas, sometimes Asia). Having residency, tax residency in a high EU country is costly and the only benefit (for me personally) is access to high standard of health care.

I want to
- optimize my net income (minimize my corporate / personal income tax burden, maximize possible deductions, minimize accounting time & efforts)
- retain access to best-of-EU health care
- retain my multi-polar lifestyle (staying in a country max. 3 months per year)

My current plan:
- Cut ties with Austria
- Bulgarian EOOD as personal holding, with subsidiaries:
- Bulgarian EOOD for my IT business
- additional projects where I'm a shareholder can be in Estonia, Germany, ...

What are other decent options? I'm open for good advice.
 
As an EU citizen, the easiest low-tax options are Cyprus and Malta, and possibly Ireland.

Cyprus: form a local company, pay 12.5% corporate income tax, pay yourself tax free dividends, pay social security of 2.65% (max 4,770 EUR/year). If you want a holding company, you can of course form one of those as well. You can obtain tax residence by just staying there 60 days per year and not being tax resident elsewhere.

Malta: form a local company and overseas holding company, pay 35% tax but get 6/7 of it back (or arrange to only pay the 1/7th) for an effective net tax of 5%, and then pay yourself dividends from the overseas holding company.

Both require annual audits for companies, which is a mixed blessing. It means there is more accounting work but the upside is there are many service providers competing on the market. Just pay someone to do the books for you.

Healthcare is not best of EU in either of them. They're not bad, but you'd be wise to invest in some form of international private insurance.

Both are pretty good for frequent travel. Daily flights to major European airports for layovers (and many smaller destinations) and some direct routes to Middle East, Africa, and Asia.
 
As an EU citizen, the easiest low-tax options are Cyprus and Malta, and possibly Ireland.

Cyprus: form a local company, pay 12.5% corporate income tax, pay yourself tax free dividends, pay social security of 2.65% (max 4,770 EUR/year). If you want a holding company, you can of course form one of those as well. You can obtain tax residence by just staying there 60 days per year and not being tax resident elsewhere.

Malta: form a local company and overseas holding company, pay 35% tax but get 6/7 of it back (or arrange to only pay the 1/7th) for an effective net tax of 5%, and then pay yourself dividends from the overseas holding company.

Both require annual audits for companies, which is a mixed blessing. It means there is more accounting work but the upside is there are many service providers competing on the market. Just pay someone to do the books for you.

Healthcare is not best of EU in either of them. They're not bad, but you'd be wise to invest in some form of international private insurance.

Both are pretty good for frequent travel. Daily flights to major European airports for layovers (and many smaller destinations) and some direct routes to Middle East, Africa, and Asia.
How much days are you required to stay in Malta ?
 
So, I'm kinda losing sight of the forest amidst the trees.

Situation:
- Citizen of Germany
- tax residency & IT business (sole proprietorship) in Austria
- small properties (apartments) in several EU countries
- not married, no kids

Over the past years, my lifestyle has been multi-polar (between EU and Americas, sometimes Asia). Having residency, tax residency in a high EU country is costly and the only benefit (for me personally) is access to high standard of health care.

I want to
- optimize my net income (minimize my corporate / personal income tax burden, maximize possible deductions, minimize accounting time & efforts)
- retain access to best-of-EU health care
- retain my multi-polar lifestyle (staying in a country max. 3 months per year)

My current plan:
- Cut ties with Austria
- Bulgarian EOOD as personal holding, with subsidiaries:
- Bulgarian EOOD for my IT business
- additional projects where I'm a shareholder can be in Estonia, Germany, ...

What are other decent options? I'm open for good advice.
doesn't Austria have a 27.5% exit tax on unrealized gains?
 
Stay in Romania for 183 for residential purpose and that 10% tax, 5% for dividends, 1 or 3 % for small business with less than 1 million euro and you can have costs with taxes at 6 to 8 %.
I've been told that like Malta, also Romania and Bulgaria, doens't check about your physical presence in the country.

So it's really hard to brake this rule.

Anyway Romania or Malta are probably the best way to go.

Second choice would be Cyprus or Bulgaria.

Another thing is that if you want to move a bit outside Europe, than Dubai, Thailand, Malaysia are good options
 
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