Try to think out of the box. Deloitte is the epitome of conventional thinking (when not incompetence).We have used Deloitte for nearly a lifetime, and they’ve always ensured that the tax authorities are kept at bay while opening doors to bank credit when needed. Additionally, they’ve been excellent at optimizing my personal tax burden and, above all, have a solid understanding of my goals and preferences.
That said, I can see from the responses in this thread that there is room for alternative approaches to Deloitte’s suggestions, and I’ve truly appreciated reading all your insightful replies. I’ve now reached out to advisors in Liechtenstein to explore the potential for a setup there. I’m also still considering a company in Switzerland as a public-facing entity and have requested a thorough review of the tax disadvantages.
Please feel free to share more advice. I’ve contributed to the forum with a lifetime membership as a way to give back to this fantastic platform and to show that I’m serious.
Two problems I see in these proposal: 1. To transfer part of full ownership of the operating company might be taxable if not done with proper transfer pricing. Possibility (nothing more, please check) of a share swap or forming a European SE could possibly avoid that.
Great point.. so a lot depends on the persons individual tax residence.2. With reference to Lichtenstein nobody indicated the WHT on the dividends coming out to the holding company, only the individual’s personal income tax liability from getting out the money from the holding company. As an EEA country the parent/subsidiary directive cannot be applied, and for this possible solution an EU holding company might be better than Lichtenstein.
And this is where my very skilled tax advisors come into play, providing me with immense value by ensuring everything is done correctly from the start. You are absolutely right, it’s not everything that users here can or remember to share, which is why I use the thread as a hint and then conduct my own research.Two problems I see in these proposal: 1. To transfer part of full ownership of the operating company might be taxable if not done with proper transfer pricing. Possibility (nothing more, please check) of a share swap or forming a European SE could possibly avoid that. 2. With reference to Lichtenstein nobody indicated the WHT on the dividends coming out to the holding company, only the individual’s personal income tax liability from getting out the money from the holding company. As an EEA country the parent/subsidiary directive cannot be applied, and for this possible solution an EU holding company might be better than Lichtenstein.
And I might be wrong
he did, it's an massive budget OP has for advisorsWhich you will now share so we can judge what you paid them for
Definitely. As far as I understand, we are dicussing company strategies here, until now. Personal taxation is another issue, not taken into account yet. Of course, these issues are linked, to some extent.a lot depends on the persons individual tax residence.
I completely agree with Sols that a Danish company, in terms of prestige, is on the same level as Switzerland, Sweden, Norway, or the Netherlands for that matter. However, I don’t know why Eliasit is so strongly opposed.Danish holding companies can be quite attractive for exits. There are special rules you can use to end up paying little to no tax in the event of an exit. I've seen a couple successfully executed.
Don't live in Denmark, though. Having a Danish holding company is a different story entirely from living there or even doing active trading business through a Danish company.
It is not a significant budget considering the total revenue and the corporate structure, which is classified as moderately complex. For a small business, however, it might understandably seem like a substantial amount.he did, it's an massive budget OP has for advisors
Many Danish here guy have severe problems with the Skat. The Danish tax authority had a lot of demands and then, they left. You can check @JohnLocke's case hereHowever, I don’t know why Eliasit is so strongly opposed.
we opted for Switzerland with a Luxembourg parent company as the holding entity
Thank you for sharing @benq, appreciate it.It is not a significant budget considering the total revenue and the corporate structure, which is classified as moderately complex. For a small business, however, it might understandably seem like a substantial amount.
For the sake of clarity and to conclude this discussion, we opted for Switzerland with a Luxembourg parent company as the holding entity. Based on our calculations and the conclusions drawn by our financial strategists, this approach represents a solution that meets the conditions we set for our business while ensuring we maintain credibility with our customers and business partners.
As an EEA country the parent/subsidiary directive cannot be applied, and for this possible solution an EU holding company might be better than Lichtenstein.
For the sake of clarity and to conclude this discussion, we opted for Switzerland with a Luxembourg parent company as the holding entity. Based on our calculations and the conclusions drawn by our financial strategists, this approach represents a solution that meets the conditions we set for our business while ensuring we maintain credibility with our customers and business partners.
Liechtenstein has a robust network of concluded DTAsPretty sure that Liechtenstein is part of the PSD.
That sounds like a really good decision and structure, even without knowing the specific factors behind your choice. However, as you mentioned, the thread was created more for inspiration than for advice or guidance.It is not a significant budget considering the total revenue and the corporate structure, which is classified as moderately complex. For a small business, however, it might understandably seem like a substantial amount.
For the sake of clarity and to conclude this discussion, we opted for Switzerland with a Luxembourg parent company as the holding entity. Based on our calculations and the conclusions drawn by our financial strategists, this approach represents a solution that meets the conditions we set for our business while ensuring we maintain credibility with our customers and business partners.
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