€700K - Where incorporate and live as digital nomade

[GrumpyMess]

No CFC rules for private individuals

"A company is resident if its seat or place of effective management is in Slovakia", so even without CFC rule the offshore company may be called upon to pay taxes. In the future, the CFC law may also include individuals. Also an exit tax exists.

 

[momordica]

"A company is resident if its seat or place of effective management is in Slovakia", so even without CFC rule the offshore company may be called upon to pay taxes. In the future, the CFC law may also include individuals. Also an exit tax exists.

This rule is not for the UAE setup I mentioned, read the DTT between Slovakia and UAE. However, I never heard of anyone who was called to pay taxes from offshore companies. Many ppl looking for security do a Cyprus non-resident company with an office in Malta. That completely avoid the rule you mentioned. Yes, in the future, the CFC law may also include individuals. But in the future also UAE can impose corporate tax or EU tax harmonization can happen. Considering the political climate in the country, it is very unlikely.
Btw. Your 3% Romania setup will not work for her, because 3% is for non-consultancy income.

 

[Financelady45]

Friends,

Thanks so much for your (all) inputs, I am so happy. I have sorted my idea in two groups:

OPTION 1 (HOMETOWN LTD)
1. Set up a LTD in my home country and buy a small flat where to put all the asset and residency
2. Have myself as Director and get a salary (It will cost me money as I will have to pay also the social insurance, taxes, etc). AND / OR
3. Hire a family member and use his fiscal benefits for the first 3 year + Buy a nice car and some other relevant expenses
4. Pay LTD Corporate Taxes 26% on the remaining income in my home country :-(
5. Repeat the above model for the upcoming years and keep all future income in the LTD
6. Use the LTD to buy properties
7. Have the LTD to rent all properties
8. Get rental income into the LTD
9. Pay myself a salary (Basically the rental income)

If we consider the following:
€675K NET (After Taxes + Saving)
5.5% Income from Rental=€37K

A: If I keep this income taxable in my home country I will have probably approx €20K at my disposal (after taxes).
B. I will be able to travel and relocate in low costs countries and or countries where offer exception under an amount and live as digital nomade.

--->What do you think about the above schema? What can be the risk?

Questions:

1. If I get married OR I have some private circumstance, the LTD assets will be protected, they will be able only to attack me for my income as Director, correct?
2. To calculate my worth and aliments a judge can consider also the assets in my LTD?


OPTION 2 (UAE + EU ENTITY)
1. Set-up a FZE company in the UAE to invoice your clients. No acccouting, 0% CPT
2. Set-up a LLC company in Slovakia just to pay yourself a minimal wage. Gross is 520 eur and you will get 420 eur. For the 100 eur the state will take, you get relatively decent healthcare (or at least value for the money) and also right for government provided pension when you reach the certain age, the amount will be symbolic because you pay minimal levies but still you will be a net receiver from public system.
3. Disclose your life documentable life in the country of your current tax residency (rent, bank accounts...).
4. Rent / Buy place in Slovakia. You become a tax resident in Slovakia if you spend 180 days per calendar year in the country OR if you have "center of vital interests" in the country - which you will have bc of job, rent and no economic ties to any other country. If you would consider to live in the country, it is decent option. Cost of living is comparable to Poland/Hungary. If you are tired of huge cities, Bratislava offer some balance. From the capital town it is one hour to Vienna, two hours Budapest by car and Prague is reachable in 4 hours by train. Bratislava region is the 3rd richest region in the EU. Eurozone country. No CFC rules for private individuals. Slovakia is still the fastest growing economy since they joined the EU.
5. Pay yourself a dividend from your UAE company. 0% withholding tax imposed by UAE, 7% tax on dividends under DTT in Slovakia.
6. Invest in the real estate of your choice. The income derived from rent is treated as capital gains, taxed at the rate 19% (you will not pay social levies on this). If you will decide to sell the property (and held the property for at least 2 years) you will pay 0% tax. 0% tax rate also applies to sell of shares bought on the regulated market (if you hold them at least 12 months). You can buy stuff up to 15k eur in cash, physical gold worth of 10k per transaction also in cash... sell of physical gold is taxed at the rate of 0%.

Questions:
1. I have heard in Europe that if a UAE company has no substance, it will be considered as EU Company and a lot of taxes / penalities will be due.
2. I love the idea to have the income tax frees and pay myself a divident (taxable) but what if the above scenario will be applied (tax elusion)?
3. So the UAE company will be the owner of all properties right?
4. Anyone has applied this schema?


What about IRELAND or SWITZERLAND?

 

[Shlomo]

You have received many good suggestions, but I feel you keep tilting towards some falsely-perceived sense of security in countries which are very expensive, while you discard other places based on out-of-date prejudice. Most likely, picking those places you perceive as "safe" will not be safer at all, but to the contrary in many such countries the tax authorities can be extremely predatory. Laws often change, and it is usually to the worse. Consequently, the already high taxes and fees became even higher.

No matter where we look, these "old economies" such as the USA, Switzerland or the UK, they will NOT offer attractive rental yields, low taxes, low crime rates, and so on. There are some faraway countries that try to attract foreigners, such as the UAE, Malaysia, Belize, and so on; however, these places are risky exactly because they are faraway, and you are so dependent upon a network of middlemen who you have to trust. As a result, the fees incurred are often huge, and these are ongoing fees. What do you do for example when you want to liquidate the company? It can be incredibly complicated and expensive.

In my opinion, just like so many other people mentioned, you should probably look at Central Europe. If you want to combine it with a good place to live, relatively cheap cost of living and high crime safety, in addition to decent rental yields, it is a good choice. Another option not so far away would be Georgia. It is really a very attractive option, and almost too good to be true, but it is not (only it is less well-known compared to say Cyprus). Georgia is also not ideal as an offshore jurisdiction, but in your case this is not applicable.

 

[JohnLocke]

There are many places in Europe where the tax is low and where it is safe to be i.e. Malta, Cyprus, Switzerland, Lichtenstein, Luxembourg! Just pick one and find someone in the country that can help you. Almost any of these countries have service providers that help with relocation!

 

[Shlomo]

There are many places in Europe where the tax is low and where it is safe to be i.e. Malta, Cyprus, Switzerland, Lichtenstein, Luxembourg! Just pick one and find someone in the country that can help you. Almost any of these countries have service providers that help with relocation!

You are right that all these countries can offer these things, but if you start adding more requirements it is a different situation. For example, the thread starter wants to live off rental income. Would Switzerland be a good choice then? Definitely not. What about cost of living? Will she rent an apartment in for example Luxembourg? The rental income would hardly cover her own rent. Will she buy apartments elsewhere and rent them out? Not a good idea. I say again, for the specific requirements she has, she should look most closely at Central Europe.

 

[Financelady45]

You are right that all these countries can offer these things, but if you start adding more requirements it is a different situation. For example, the thread starter wants to live off rental income. Would Switzerland be a good choice then? Definitely not. What about cost of living? Will she rent an apartment in for example Luxembourg? The rental income would hardly cover her own rent. Will she buy apartments elsewhere and rent them out? Not a good idea. I say again, for the specific requirements she has, she should look most closely at Central Europe.

Yes, I would like to live with rental income and have at least 5% - 5.5% rental income before taxes. One consultant said I have to buy a small property in the country which I want to make the center of my interest so that no issues in future. In Switzerland there are low taxes but high expenses, properties, etc.

 

[GrumpyMess]

This rule is not for the UAE setup I mentioned, read the DTT between Slovakia and UAE. However, I never heard of anyone who was called to pay taxes from offshore companies.

Article 4, (3). The company is resident there, where it's place of effective management is. In this example Slovakia. I also haven't heard of such cases in countries which don't have CFC rule, but it isn't a guarantee.

Many ppl looking for security do a Cyprus non-resident company with an office in Malta. That completely avoid the rule you mentioned

By office you mean just an adress or the hired director with physical office?

Another option not so far away would be Georgia. It is really a very attractive option, and almost too good to be true, but it is not (only it is less well-known compared to say Cyprus). Georgia is also not ideal as an offshore jurisdiction, but in your case this is not applicable.

Some update on my previous post about Georgia. As I discovered it has a lot of typical 3rd word country problems such as corruption and it's definitely not a good place to live, but it seems these problems don't bother people who use it only as a country to get a residence.

 

[momordica]

Article 4, (3). The company is resident there, where it's place of effective management is. In this example Slovakia. I also haven't heard of such cases in countries which don't have CFC rule, but it isn't a guarantee.

By office you mean just an adress or the hired director with physical office?

Some update on my previous post about Georgia. As I discovered it has a lot of typical 3rd word country problems such as corruption and it's definitely not a good place to live, but it seems these problems don't bother people who use it only as a country to get a residence.

I know ppl in Slovakia with the UAE setup and no problem so far. Tax authorities focus more on VAT. However, I suggested the UAE only bc 0% CPT and 0% WHT, people in Slovakia do also a Cyprus non-resident company without any problem. But the setup with effective place of management in Malta is legally bulletproof. You need a director from Malta and a physical address (which cost more than UAE setup). When a beneficial owner need to pay himself dividends from such company, he just appoint a Cyprus director to access DTT.

Another option, when she will make herself a tax resident of Slovakia is:
1. Simply setup Seychelles/Belize (ppl here will advise which is easier and better). Invoice clients through this company. Tax authorities will have no chance to get any information even if they will want to (and they will not) bc of no DTT and no exchange of informations. You do not have to use nominee services bc of no CFC.
2. Seychelles company will incorporate in Slovakia. Through this company you can buy real-estate in Slovakia. Seychelles company will own 90% and you as a private individual will own 10%.
3. You will pay corporate income tax from rent income and the dividend tax you will pay yourself as a director (you need to own some shared capital as a private individual, bc dividend would be otherwise treated as ordinary income 19%).

So, you will invest 100% of your consulting income (no tax loses).
Lets say you will make 30k eur / year from rent.
- you will pay yourself a minimal wage 520 eur x 12 = 6240 eur from this you will get 5040 eur to your private bank account (rest is healthcare and social levies). This will be an expense of the company.
- you can also buy a car, do some travelling as company expenses to lower your tax base etc.
- buy of the real estate is also tax expense, but every year you can claim only 1/20 of the value of the property when you bought it. You can do this for 20 years.
- so if you buy 3 apartments each worth of 200k... you can claim tax expenses 30k every year (for 20 years)
- your tax base will be -6240 eur
- after paying CPT (which is now ridiculously high 21%, but will get lower) which will be in your case 0 eur (for at least 20 years) and then 7% dividend tax (which is promised to be abolished again) you will left with 22096 eur.
From the whole 30k you should get around 27136 eur to your private bank account (rest will be taxes and social levies). So the effective tax rate will be around 9,54%.

PROS
- You will invest the whole sum (without the 7% loss on dividends from UAE)
- Assets (or 90% at least) protected from marriage etc., bc owned by Seychelles company
- Legally is this setup slightly better than with the UAE

CONS
- If you will decide to sell the property, you will have to pay CPT, as a private individual there is no tax
- If you rent as a private individual you pay 19% tax, as a company you have to pay CPT + dividend tax (which you can minimize through tax expenses)
- When you will sell the property you will have to sell it with VAT + 20%.
- Soon or later will the EU push countries like Slovakia adapt some standardized CFC rules (you will have to appoint nominees then or better in the meantime work on getting the slovak company under your full control).

 

[Financelady45]

I know ppl in Slovakia with the UAE setup and no problem so far. Tax authorities focus more on VAT. However, I suggested the UAE only bc 0% CPT and 0% WHT, people in Slovakia do also a Cyprus non-resident company without any problem. But the setup with effective place of management in Malta is legally bulletproof. You need a director from Malta and a physical address (which cost more than UAE setup). When a beneficial owner need to pay himself dividends from such company, he just appoint a Cyprus director to access DTT.

Another option, when she will make herself a tax resident of Slovakia is:
1. Simply setup Seychelles/Belize (ppl here will advise which is easier and better). Invoice clients through this company. Tax authorities will have no chance to get any information even if they will want to (and they will not) bc of no DTT and no exchange of informations. You do not have to use nominee services bc of no CFC.
2. Seychelles company will incorporate in Slovakia. Through this company you can buy real-estate in Slovakia. Seychelles company will own 90% and you as a private individual will own 10%.
3. You will pay corporate income tax from rent income and the dividend tax you will pay yourself as a director (you need to own some shared capital as a private individual, bc dividend would be otherwise treated as ordinary income 19%).

So, you will invest 100% of your consulting income (no tax loses).
Lets say you will make 30k eur / year from rent.
- you will pay yourself a minimal wage 520 eur x 12 = 6240 eur from this you will get 5040 eur to your private bank account (rest is healthcare and social levies). This will be an expense of the company.
- you can also buy a car, do some travelling as company expenses to lower your tax base etc.
- buy of the real estate is also tax expense, but every year you can claim only 1/20 of the value of the property when you bought it. You can do this for 20 years.
- so if you buy 3 apartments each worth of 200k... you can claim tax expenses 30k every year (for 20 years)
- your tax base will be -6240 eur
- after paying CPT (which is now ridiculously high 21%, but will get lower) which will be in your case 0 eur (for at least 20 years) and then 7% dividend tax (which is promised to be abolished again) you will left with 22096 eur.
From the whole 30k you should get around 27136 eur to your private bank account (rest will be taxes and social levies). So the effective tax rate will be around 9,54%.

PROS
- You will invest the whole sum (without the 7% loss on dividends from UAE)
- Assets (or 90% at least) protected from marriage etc., bc owned by Seychelles company
- Legally is this setup slightly better than with the UAE

CONS
- If you will decide to sell the property, you will have to pay CPT, as a private individual there is no tax
- If you rent as a private individual you pay 19% tax, as a company you have to pay CPT + dividend tax (which you can minimize through tax expenses)
- When you will sell the property you will have to sell it with VAT + 20%.
- Soon or later will the EU push countries like Slovakia adapt some standardized CFC rules (you will have to appoint nominees then or better in the meantime work on getting the slovak company under your full control).

Hello,

Thanks so much for this important input, you seem to know exactly what you are saying and I love this.
You really make think about the whole situation, thanks!

A few points:

1)UAE = Extra EU UAE = 0 Taxes
2)Cyprus Non Resident Company= EU Friendly with VAT Number etc.
3)Seychelles / Belize = Not a good reputation

If 1) 2) 3) will be created and then incorporated in Slovakia then:

Q1: What happen if those countries will:
A) Increase Taxes
B) Exchange information about the Owner of the company having a EU Pass. As far as I know Western Europeans Tax Authorities are extremely against those entities if there is no substance and are used only to bypass taxations
C) change the exchange agreements, DBA, etc

Q2: Why do you suggest a 90/10 Ownership spliced between business and private?

Lets suppose my LTD (no matter in what country 1) 2) 3)) will get 30K from the rental income:

30,000 Income
6,240 EUR (Director Salary) -
___________
23760 EUR

600,000 / 20 Years = 30,000

-6240 EUR (Business Income)
0 Corporate Taxes
OK

Lets suppose the same company is incorporated in a Western EU country where the corporate tax is for example 25% + 20% -30% divided taxes:

30,000 Rental Income -
28,000 EUR (Directory Salary) -> Approx 18,000 - 20,000 NET ((2/3 Income)) after deduction of insurance, retirement account, expenses like director car, some travels, half of the home office surface, etc)
2,000 Other Business Expenses

0,000 EUR (income)
600,000 / 20 Years = 30,000
______
-30,000 EUR (Business Income)= No Divided Taxes = No Corporate Taxes

-> So basically even if the company reside in a high taxation country in Western Europe. the Director can get a salary according to the needs and expenses as there is a fiscal progression and having the Director have some deductible costs, it might be possible to reach a similar result as in Slovakia). This structure will also allow the director to live in a different country (digital nomad) for some times and eventually get back to the homepage in a legit way and by saving a lot of taxes.

Let me know your comments on this, thanks!

 

[GrumpyMess]

I know ppl in Slovakia with the UAE setup and no problem so far.

I know that people in the neighbor Czech Republic have closed their offshore corps due to inefficiency. The laws there are pretty the same

But the setup with effective place of management in Malta is legally bulletproof. You need a director from Malta and a physical address (which cost more than UAE setup). When a beneficial owner need to pay himself dividends from such company, he just appoint a Cyprus director to access DTT.

Yes, it's bulletproof but costs quite a lot.

1. Simply setup Seychelles/Belize (ppl here will advise which is easier and better). Invoice clients through this company. Tax authorities will have no chance to get any information even if they will want to (and they will not) bc of no DTT and no exchange of informations. You do not have to use nominee services bc of no CFC.

Tax authorities will definitely have a solution to get any information even if no DTT exists, they simply get the information from AEOI or direct request to bank.

people in Slovakia do also a Cyprus non-resident company without any problem

Is Cyprus non resident company allowed to buy property in EU? And if yes, is this a solution not to setup a local company in Slovakia?

 

[momordica]

2) A Cyprus non-resident company can not have a VAT number, but sure the EU company looks better...
3) Yeah, I forgot that your clients may have problem with paying invoices to Seychelles/Belize

In the case you would go through a cyprus non-resident company, you would just invoice your clients... then appoint a Cyprus director to access double tax treaties and pay yourself all income through dividends in Slovakia (taxed 7%)... you would continue investing as a private individual like suggested in my innitial post with the UAE FZE company.

A.) Any country can raise taxes, incl. Slovakia, Poland, France or Spain. Central European countries do have lower productivity than their Western European counterparts so the lower taxes are essential to maintain competitiveness to attract foreign investments, therefore they will not ruin their business model. You can look at average annual GDP growth in Czechia, Slovakia or Poland and their debt to GDP ratio levels and you get a clear picture that they do not have to raise taxes... unlike Western European countries.
B.) / C.) In the case of Slovakia this will not be an issue, bc of no CFC rules for private individuals, so as a slovak tax resident you can bypass whatever you want. The only issue can be as GrumpyMess mentioned "A company is resident if its seat or place of effective management is in Slovakia". In the case of a Cyprus non-resident with Malta office and director it is clear bc effective management is in Malta. If the UAE will change its laws and they will release who is 100% shareholder/director, I wish good luck to slovak tax authorities to prove where was the effective management when the profit was made (bc no accounting in UAE companies etc.)... and frankly this is scify. A couple weeks ago they caught a guy with 500k in cash, who has officially on his pay roll 1k eur income, and they had to let him go bc he said "I found the bag with money in the house of my grandmother, which passed a few years ago".

Q2: Because you need to have some share capital in the slovak company to get dividends with the 7% rate, otherwise it would be 19%.

In my Seychelles/Slovakia setup you get 27k from 30k, in your domestic country it would be 20-21k from 30k. In your first post you stated live from 2-3k month / offshore, so this could make a difference.

Do you mind sharing which country are you in now? 25%, I suppose Netherlands?

 

[momordica]

I know that people in the neighbor Czech Republic have closed their offshore corps due to inefficiency. The laws there are pretty the same

I know guys who still run funds through BVI and pay themselves small salaries through CZ companies. They have never paid any CPT in CZ. Most closed bc CZ now also offer holding regime if the classic conditions are met, but for online business is offshore still essential. Depends on scale. On small scale you rather pay 19% than costly structures.

Yes, it's bulletproof but costs quite a lot.

Yep

Tax authorities will definitely have a solution to get any information even if no DTT exists, they simply get the information from AEOI or direct request to bank.

Yes, they just do not do it. As you can see in the picture. One particular bank "Postova Banka" encourages its clients to setup companies in Cyprus, they lent to such Cyprus non-resident setups owned by their clients (95% Slovaks) money worth of more than 3bln eur to this day, 25% of all money they lent. They normally do business through those companies and pay no taxes.

Is Cyprus non resident company allowed to buy property in EU? And if yes, is this a solution not to setup a local company in Slovakia?

I do not know this.

Btw. You mentioned the micro Romanian company with 3%. Do you know about VAT rules in Romania? A software company selling software (digital sales) to final customers outside the EU. So B2C transactions, outside of the EU (Asia, South America, North America). Does this company have to charge VAT on such transactions?

 

[JohnLocke]

2)Cyprus Non Resident Company= EU Friendly with VAT Number etc.

No it's not possible to register a non resident Cyprus company for VAT!

Yes, they just do not do it.

I would not bet my last coin on that, sorry but this is too weak.

 

[Financelady45]

2) A Cyprus non-resident company can not have a VAT number, but sure the EU company looks better...
3) Yeah, I forgot that your clients may have problem with paying invoices to Seychelles/Belize

In the case you would go through a cyprus non-resident company, you would just invoice your clients... then appoint a Cyprus director to access double tax treaties and pay yourself all income through dividends in Slovakia (taxed 7%)... you would continue investing as a private individual like suggested in my innitial post with the UAE FZE company.

A.) Any country can raise taxes, incl. Slovakia, Poland, France or Spain. Central European countries do have lower productivity than their Western European counterparts so the lower taxes are essential to maintain competitiveness to attract foreign investments, therefore they will not ruin their business model. You can look at average annual GDP growth in Czechia, Slovakia or Poland and their debt to GDP ratio levels and you get a clear picture that they do not have to raise taxes... unlike Western European countries.
B.) / C.) In the case of Slovakia this will not be an issue, bc of no CFC rules for private individuals, so as a slovak tax resident you can bypass whatever you want. The only issue can be as GrumpyMess mentioned "A company is resident if its seat or place of effective management is in Slovakia". In the case of a Cyprus non-resident with Malta office and director it is clear bc effective management is in Malta. If the UAE will change its laws and they will release who is 100% shareholder/director, I wish good luck to slovak tax authorities to prove where was the effective management when the profit was made (bc no accounting in UAE companies etc.)... and frankly this is scify. A couple weeks ago they caught a guy with 500k in cash, who has officially on his pay roll 1k eur income, and they had to let him go bc he said "I found the bag with money in the house of my grandmother, which passed a few years ago".

Q2: Because you need to have some share capital in the slovak company to get dividends with the 7% rate, otherwise it would be 19%.

In my Seychelles/Slovakia setup you get 27k from 30k, in your domestic country it would be 20-21k from 30k. In your first post you stated live from 2-3k month / offshore, so this could make a difference.

Do you mind sharing which country are you in now? 25%, I suppose Netherlands?

Hello Friend!

What I LIKE from your schema:

UAE / Belize / Seychells = No Taxes
SK = 7% Dividend

What I DO NOT LIKE:

Uncertain Future:
A) Tax Authorities of Western Countries can be really aggressive if they see that a national is trying to use this kind of structure
B) Also there is an inversion of the proof in case of claim, the Director will need to demonstrated that this structure has a substance which is not easy for certain reasons

Under my schema, even if Netherlands charge 25% Corporate Taxes and high dividends

30,000 Rental Income -
28,000 EUR (Directory Salary) -> Approx 18,000 - 20,000 NET ((2/3 Income)) after deduction of insurance, retirement account, expenses like director car, some travels, half of the home office surface, etc)
2,000 Other Business Expenses

0,000 EUR (income)
600,000 / 20 Years = 30,000


-> My above “local” scenario Is GOOD if we only consider that there is no risk with local authorities, relocation (if I am going for digital nomad) a few years, decent social service, insurance, pension etc,no stress worries about new DBA, common reporting agreements, etc.
->My scenario is really BAD if the local LTD will be selling the properties as the money will still be inside the LTD and the only way to get it out is by paying to the Director (myself) salaries (where I need to deduct social costs, pension, etc) or by paying HUGE dividends on it.
I do not see any reason why the LTD should be liquidated and sell the properties but with your SK scenario the pain would be just 7%.

What do you think about this?

 

[Macky]

2) A Cyprus non-resident company can not have a VAT number, but sure the EU company looks better...
3) Yeah, I forgot that your clients may have problem with paying invoices to Seychelles/Belize

In the case you would go through a cyprus non-resident company, you would just invoice your clients... then appoint a Cyprus director to access double tax treaties and pay yourself all income through dividends in Slovakia (taxed 7%)... you would continue investing as a private individual like suggested in my innitial post with the UAE FZE company.

A.) Any country can raise taxes, incl. Slovakia, Poland, France or Spain. Central European countries do have lower productivity than their Western European counterparts so the lower taxes are essential to maintain competitiveness to attract foreign investments, therefore they will not ruin their business model. You can look at average annual GDP growth in Czechia, Slovakia or Poland and their debt to GDP ratio levels and you get a clear picture that they do not have to raise taxes... unlike Western European countries.
B.) / C.) In the case of Slovakia this will not be an issue, bc of no CFC rules for private individuals, so as a slovak tax resident you can bypass whatever you want. The only issue can be as GrumpyMess mentioned "A company is resident if its seat or place of effective management is in Slovakia". In the case of a Cyprus non-resident with Malta office and director it is clear bc effective management is in Malta. If the UAE will change its laws and they will release who is 100% shareholder/director, I wish good luck to slovak tax authorities to prove where was the effective management when the profit was made (bc no accounting in UAE companies etc.)... and frankly this is scify. A couple weeks ago they caught a guy with 500k in cash, who has officially on his pay roll 1k eur income, and they had to let him go bc he said "I found the bag with money in the house of my grandmother, which passed a few years ago".

Q2: Because you need to have some share capital in the slovak company to get dividends with the 7% rate, otherwise it would be 19%.

In my Seychelles/Slovakia setup you get 27k from 30k, in your domestic country it would be 20-21k from 30k. In your first post you stated live from 2-3k month / offshore, so this could make a difference.

Do you mind sharing which country are you in now? 25%, I suppose Netherlands?

Can you please PM me ? I am interested to talk privately if possible. Want to establish this Slovakia Ltd. + UAE setup. Any advice from you is welcome.

 

[GrumpyMess]

Btw. You mentioned the micro Romanian company with 3%. Do you know about VAT rules in Romania? A software company selling software (digital sales) to final customers outside the EU. So B2C transactions, outside of the EU (Asia, South America, North America). Does this company have to charge VAT on such transactions?

As a general rule in EU export of such services outside of the EU is VAT-free, the same applies to Romania

 

[Macky]

What about this one:

1. Move to Cyprus, apply for non-dom tax residence for you as a private person. Rent a flat/house for 2-3 months to make it 100% legal and bulletproof and dont live anywhere else for more than 183days...
2. Create LLP in UK and invoice from UK
3. As tax resident of Cyprus you will pay zero tax but consult this setup with a tax advisor first.

Enjoy life, and come back home after x years with all the money you earned.

 

[TurnedToRobot]

1. Set-up a FZE company in the UAE to invoice your clients. No acccouting, 0% CPT
2. Set-up a LLC company in Slovakia just to pay yourself a minimal wage. Gross is 520 eur and you will get 420 eur. For the 100 eur the state will take, you get relatively decent healthcare (or at least value for the money) and also right for government provided pension when you reach the certain age, the amount will be symbolic because you pay minimal levies but still you will be a net receiver from public system.
3. Disclose your life documentable life in the country of your current tax residency (rent, bank accounts...).
4. Rent / Buy place in Slovakia. You become a tax resident in Slovakia if you spend 180 days per calendar year in the country OR if you have "center of vital interests" in the country - which you will have bc of job, rent and no economic ties to any other country. If you would consider to live in the country, it is decent option. Cost of living is comparable to Poland/Hungary. If you are tired of huge cities, Bratislava offer some balance. From the capital town it is one hour to Vienna, two hours Budapest by car and Prague is reachable in 4 hours by train. Bratislava region is the 3rd richest region in the EU. Eurozone country. No CFC rules for private individuals. Slovakia is still the fastest growing economy since they joined the EU.
5. Pay yourself a dividend from your UAE company. 0% withholding tax imposed by UAE, 7% tax on dividends under DTT in Slovakia.
6. Invest in the real estate of your choice. The income derived from rent is treated as capital gains, taxed at the rate 19% (you will not pay social levies on this). If you will decide to sell the property (and held the property for at least 2 years) you will pay 0% tax. 0% tax rate also applies to sell of shares bought on the regulated market (if you hold them at least 12 months). You can buy stuff up to 15k eur in cash, physical gold worth of 10k per transaction also in cash... sell of physical gold is taxed at the rate of 0%.

The fee to setup a UAE companu is roughly 12,000 euro and 15,0000 per year! Why would someone go that route unless you have millions available?

 

[momordica]

Hello Friend!

What I LIKE from your schema:

UAE / Belize / Seychells = No Taxes
SK = 7% Dividend

What I DO NOT LIKE:

Uncertain Future:
A) Tax Authorities of Western Countries can be really aggressive if they see that a national is trying to use this kind of structure
B) Also there is an inversion of the proof in case of claim, the Director will need to demonstrated that this structure has a substance which is not easy for certain reasons

Under my schema, even if Netherlands charge 25% Corporate Taxes and high dividends

30,000 Rental Income -
28,000 EUR (Directory Salary) -> Approx 18,000 - 20,000 NET ((2/3 Income)) after deduction of insurance, retirement account, expenses like director car, some travels, half of the home office surface, etc)
2,000 Other Business Expenses

0,000 EUR (income)
600,000 / 20 Years = 30,000


-> My above “local” scenario Is GOOD if we only consider that there is no risk with local authorities, relocation (if I am going for digital nomad) a few years, decent social service, insurance, pension etc,no stress worries about new DBA, common reporting agreements, etc.
->My scenario is really BAD if the local LTD will be selling the properties as the money will still be inside the LTD and the only way to get it out is by paying to the Director (myself) salaries (where I need to deduct social costs, pension, etc) or by paying HUGE dividends on it.
I do not see any reason why the LTD should be liquidated and sell the properties but with your SK scenario the pain would be just 7%.

What do you think about this?

Hello,

In my opinion, Netherlands is one of the better options in the West to be incorporated. There are two CPT brackets, so you will pay 25% only on the profit above 200k, rest will be taxed with 20%. On the top, the local government approved tax cuts, so you should be taxed actually this way through Dutch LTD.

2019: 400k profit - effective rate 22%
2020: 200k profit - effective rate 16,5%
2021: 100k profit - effective rate 15%

Until you will be a tax resident of Netherlands, you will have to pay high taxes on a personal level one way or the other if you decide to sell the company or through dividends. However, it will probably happen in a very long time from now (sell of the properties), in the future which is uncertain and many things can happen until that time. Both positive and negative. You can change your tax residency then (I do not know how will Dutch tax authorities look at you, then tho).

Is it essenatial to own a physical real estate for you?

What I would persnally do... get tax residency in some no-CFC rules country. Open Seychelles/Belize/UAE/BVI... company and invoice clients. With profits I would buy REIT stocks (if real estate is desired) and dividends from stocks I would cashed through a corporate card at ATM and lived in cash... and pay no taxes at all anywhere.
Once the money will hit the EUSSR, they will squeeze you... more or less everywhere.

Btw. I am myself in the process of buying a property in NL and LOL. 6% real estate transfer tax. I do not want to know the yield if I would decide to rent.