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Is Italy still territorial tax based?
- Thread starter wellington
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Next to impossible, we are talking about 70 year olds who have lived all their lives in italy. That is the only thing I cant move or change in my set up unfortunately.
Thanks for your suggestion, its great for taxes but could be the worst thing that could happen to my childrens intellectual ability and lifestyle.
Can you elaborate how growing kid in Monaco is different (in bad prospective) to any other school in Europe?
I have seen dubai very closely, its just a bigger version of monaco and geopolitically way more unsafe than monaco. In monaco, my kids will only see expensive cars, flashy lifestyle and will never be able to settle or adjust anywhere else. Its an artificial oasis, what can you teach your kids there and what do they see on a daily basis? Paying 0% tax is not my ultimate goal, in all reasonable terms anything not more than 10% is a good number to pay in taxes and live in an actual country.
I don't find Monaco and Dubai similar.
From what can I see you can try countries like Georgia. Kids would see more poverty and will adjust better
georgia definitely not. I am seriously considering UK, somewhere outside london. I spoke to a consultant in malta, I end up paying 5% with a holding structure in cyprus, estonia or gibralter. Its not that bad.I don't find Monaco and Dubai similar.
From what can I see you can try countries like Georgia. Kids would see more poverty and will adjust better
The UAE is one of the most militarized countries in the world so i doubt it's really unsafe geopolitically. Iran trying to nuke the place would be signing their own death warrant, and the saudis are allies. Only real rivals in the area for them are the Qataris and they're way too small to have any expansionist ambitions. They're also in very good terms with Israel.
Both Monaco and Dubai are not that different, one is too small and the other is surrounded by sand, both are expensive and superficial cities to live in. Your kids will still be surrounded by rich trust fund babies and sociopaths on a daily basis. Only other perk is that you can drive easily to France and Italy but the other has really cheap flights to europe so it's not really an issue anyways.
You can look at Andorra.
Is not so luxury as Monaco. However, major airport is only in Barcelona
Although I am not thinking of going to either monaco or dubai, you should look at the number of attacks from the houthi rebels in Dubai. Its very close and dangerous, although america has a base in abudhabi and still. Iran might sign their death warrant if they attack but guess what, Dubai will be over and out if that happens.
good option, but for a person who is expecting capital gains a non dom regime would work best.
yes whats the problem with that structure? malta operating company with holding company in cyprus, estonia or gibralter? effective tax rate 5%. I live in UK or ireland and claim non dom.
UK is out of EU. Do you have british passport to be able to live there? If not you will have to do whole process of visas and immigration.
Have you been often in UK or Ireland, did you see the weather there? And did you see real estate prices in London?
Anyway, it's strange structure, living in UK or Ireland with Malta, Gibraltar, Estonia companies??
This all structure seems to be very random.
Have you been often in UK or Ireland, did you see the weather there? And did you see real estate prices in London?
Anyway, it's strange structure, living in UK or Ireland with Malta, Gibraltar, Estonia companies??
This all structure seems to be very random.
Malta has good DTA's with non-dom countries including IoM, UK, Ireland etc. Also with Italy. Need to put serious economic substance in Malta of course. Also need to check all commercial business flow - DTA's etc - from customers and investors to your 3 country set up (Italy, Malta + non-dom country). Slowly slowly many countries introduce rules that say privileges in their country (like tax free dividends) depend on a minimum rate of taxing (for example 15%) paid already somewhere else. So the fine details of any structure need to be analysed carefully as what you get at first glance might not be what you are entitled to in the fine print. The current example of such changes is Malaysia wth it's so called territorial taxation system. Also, you can expect more tightening as various countries are now on partially restricted banking lists (Armenia, Hong Kong, Malaysia, etc). As said previously, the simplest structure is probably best these days for small businesses... and take the decision to pay more tax by living in a higher tax country like Italy, or to live at least for some few years in a low tax country (like Malta) with lower quality of life but chance to keep more profits... and so your structure is just 2 jurisdictions (Italy - Malta). As changes continue to happen into the future, the 2 jurisdiction structure model will be easier to manage for small businesses. (not saying your business will be small - just managing multi-jurisdictional structures is increasingly the domain of big business and the very wealthy).
I dont mind getting the right visa. Yes I have been to uk, apart from the weather it fits my criteria pretty well. London is expensive but still it has great schools and other services that I need for my business plus banking etc is great along with connectivity.
I spoke to a lawyer in malta and was suggested this structure, apparently it works very well. Maltese company is fully owned by a holding company in either estonia, gibralter or cyprus company and I pay 5% corporate tax.
I dont mind multi jurisidictions, infact I enjoy it. Yes the maltese structure has been verified by a lawyer and it works perfectly well.
Anyone who says they enjoy Muti-national structures must be an international tax lawyer or accountant or big multi-national company with lots of experience. If that's you then well done. If not then we can only wonder if you have any idea what you are talking about based on hard experiences?
Looks like you plan to have lots of income to pay for the real economic substance in 3 countries (Italy - Malta - Cyprus/Estonia). The higher your income the higher your risk of being audited and the higher your need for real economic substance across all jurisdictions. You think you are going to receive high income so naturally you are higher risk of being looked at. All my following comments are based on you having high income.
Every tax office knows all the multi-company structures. Nobody enjoys multi-jurisdictions much anymore except lawyers and accountants who profit by them (and who - to secure the sale - often do not fully advise their buyers of the real complications and current trend to ever increasing difficulties). Thousands of individuals and companies have chosen tax minimisation proposals from such experts and landed in difficulties and even court later. Today the first guiding principle is to use a multi structure that is a clear match for their economic activity.
Meaning, since you seem to have no ties in Malta or Cyprus/Estonia, therefore your 3 country company structure is clearly seen by every tax authority as a well known tax avoidance / minimisation arrangement. So just be ready to explain from a business perspective why you chose those countries. What ties does your business already have in each of them? Customers maybe? Seems Italy is fine.. but Malta and Cyprus / Estonia sound like they are just tax driven choices unless you already have established ties in those countries.
When there is significant tax dollars up for grabs, these days its always better if your business corporate structure can be shown to be commercially driven based on substance rather than select a structure to minimise tax and then try to prove you have ties there (in the selected countries) after the fact. Just saying.
What is an example of a tightening trend that might change and throw out your proposed UK - Malta - x model? The jurisdiction/s of ultimate beneficial ownership matters. If the UK Conservatives loose the next election as everyone predicts then Labour could abolish the non-dom status entirely, and then you would be fully liable as a UK tax payer or jumping country fast to avoid it. Tax tightening is happening all around the globe, so nobody can predict how long the non-dom status will stay in the UK. Sure, lots of people will say to will cost the UK to abolish the non-dom status... but over the years they have tightened the model, and these days when has common sense stopped a government that is under political and electoral pressure?
The global trend is towards abolishing such tax free and low tax benefits. The more countries in your structure the more variables you must pay to manage and hope they (your advisors) are getting it right. This is why it's probably safer to reside where you have your low tax business (like Malta in your proposed structure) to reduce the number of variables that can bring your arrangements undone. This assumes Malta's low tax offerings will survive for years into the future. It's always hard to know.
A final word about 'hoping your advisors get it right'. Many many clients of fancy Swiss financial companies ended up in court when beneficial ownership started being reported. They thought it would never happen. My advice? If anyone expects reasonably high income (not multinational level but high for an individual) then keep it simple and real, and try to avoid arrangements where the tax office will simply say hey this is all a tax errrrr avoidance structure. Be aware of the global trends and basically plan for it to get much worse and tighter. I am not a doom sayer... just been around a long time and see the trends. and we must be ready change the set of our sails to accommodate the blowing winds.
Looks like you plan to have lots of income to pay for the real economic substance in 3 countries (Italy - Malta - Cyprus/Estonia). The higher your income the higher your risk of being audited and the higher your need for real economic substance across all jurisdictions. You think you are going to receive high income so naturally you are higher risk of being looked at. All my following comments are based on you having high income.
Every tax office knows all the multi-company structures. Nobody enjoys multi-jurisdictions much anymore except lawyers and accountants who profit by them (and who - to secure the sale - often do not fully advise their buyers of the real complications and current trend to ever increasing difficulties). Thousands of individuals and companies have chosen tax minimisation proposals from such experts and landed in difficulties and even court later. Today the first guiding principle is to use a multi structure that is a clear match for their economic activity.
Meaning, since you seem to have no ties in Malta or Cyprus/Estonia, therefore your 3 country company structure is clearly seen by every tax authority as a well known tax avoidance / minimisation arrangement. So just be ready to explain from a business perspective why you chose those countries. What ties does your business already have in each of them? Customers maybe? Seems Italy is fine.. but Malta and Cyprus / Estonia sound like they are just tax driven choices unless you already have established ties in those countries.
When there is significant tax dollars up for grabs, these days its always better if your business corporate structure can be shown to be commercially driven based on substance rather than select a structure to minimise tax and then try to prove you have ties there (in the selected countries) after the fact. Just saying.
What is an example of a tightening trend that might change and throw out your proposed UK - Malta - x model? The jurisdiction/s of ultimate beneficial ownership matters. If the UK Conservatives loose the next election as everyone predicts then Labour could abolish the non-dom status entirely, and then you would be fully liable as a UK tax payer or jumping country fast to avoid it. Tax tightening is happening all around the globe, so nobody can predict how long the non-dom status will stay in the UK. Sure, lots of people will say to will cost the UK to abolish the non-dom status... but over the years they have tightened the model, and these days when has common sense stopped a government that is under political and electoral pressure?
The global trend is towards abolishing such tax free and low tax benefits. The more countries in your structure the more variables you must pay to manage and hope they (your advisors) are getting it right. This is why it's probably safer to reside where you have your low tax business (like Malta in your proposed structure) to reduce the number of variables that can bring your arrangements undone. This assumes Malta's low tax offerings will survive for years into the future. It's always hard to know.
A final word about 'hoping your advisors get it right'. Many many clients of fancy Swiss financial companies ended up in court when beneficial ownership started being reported. They thought it would never happen. My advice? If anyone expects reasonably high income (not multinational level but high for an individual) then keep it simple and real, and try to avoid arrangements where the tax office will simply say hey this is all a tax errrrr avoidance structure. Be aware of the global trends and basically plan for it to get much worse and tighter. I am not a doom sayer... just been around a long time and see the trends. and we must be ready change the set of our sails to accommodate the blowing winds.
I posted a calculation of the Italy 90% tax deduction in another thread that went into details of the total cost for this setup, could someone from this thread confirm that this is correct? Thanks
https://www.offshorecorptalk.com/threads/cbi-st-kitts-taxes.40632/post-254051
https://www.offshorecorptalk.com/threads/cbi-st-kitts-taxes.40632/post-254051
You can pay 5% tax while living in the UK? Because then I will move to Scotland. The thing that worries me about Malta is the changes they will make the next year and the 30% exit tax. Plus last weeks heatwave was kind of insane, the electricity grid suffered massively and some of my hardware was shut down. It's a really nice spot with nice people though, and the Mediterranean live is nice. Food is great too. But it feels like it will become worse to live in every single year.
Not planning on leaving yet, but if the UK would have some kind of non-dom regime with low taxes I would strongly consider moving there.
I feel that Malta is going to remove the whole imputation type system and replace it with 25% corporate income tax.
The UK really did a number on offshore as they were Malta's strongest allies in opposing tax harmonisation at the EU level. My guess is there will be 15% corporate income tax in Malta within a few years which is not great combined with 15% WHT.
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yes uk has a non dom regime for upto 6 years
malta is a great place and i considered it at a point but its too small plus suffers from a not so good reputation globally or specially in europe
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