"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.
"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.No CFC rules for private individuals
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."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.
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.
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.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.
By office you mean just an adress or the hired director with physical office?Many ppl looking for security do a Cyprus non-resident company with an office in Malta. That completely avoid the rule you mentioned
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.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.
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.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).
I know that people in the neighbor Czech Republic have closed their offshore corps due to inefficiency. The laws there are pretty the sameI know ppl in Slovakia with the UAE setup and no problem so far.
Yes, it's bulletproof but costs quite a lot.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.
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.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.
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?people in Slovakia do also a Cyprus non-resident company without any problem
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.I know that people in the neighbor Czech Republic have closed their offshore corps due to inefficiency. The laws there are pretty the same
YepYes, it's bulletproof but costs quite a lot.
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.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.
I do not know this.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?
No it's not possible to register a non resident Cyprus company for VAT!2)Cyprus Non Resident Company= EU Friendly with VAT Number etc.
I would not bet my last coin on that, sorry but this is too weak.Yes, they just do not do it.
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?
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?
As a general rule in EU export of such services outside of the EU is VAT-free, the same applies to RomaniaBtw. 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?
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?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%.
Hello,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?
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