Portugal Resident + Bulgaria Company and receive dividends

[Ssrn]

For what it's worth, consultants in Malta have told me appointing director there and having the 'office' is enough. They wouldn't even really know how much of the work you did in Portugal. And since it's dividends, you aren't being paid for completing any work.
I'm looking to verify with a pro on the Portuguese end before going forward. But Lisbob seems to think this works fine too.

Edit: the effective corporate tax rate is 35% with 30% rebate. So 5%. No dividend witholding tax.

Yes in Malta they offer directors for hire. In Romania I haven't found that. My info talking to a lawyer is that in Malta the hired directors soon need a license and will be registered in a publicly available way. So your local tax office might call it a Bluff when they see your director works for 20 other companies as well. I have not verified that info anywhere else, just came up in one conversation

 

[Jade33]

I am confused at his actual business set up, making 500k without a company? as he is looking to create one only now.....

 

[mikestachurski]

I'm not sure if there are answers here, since it's been some time. There seems to be confusion around CFC laws and such. If you live in Portugal and have your company in a country that is Whitelisted, it is not about "what they believe" or "would let you pay less tax". If the system is there, it's legal. Portugal does not have the same policy as Germany does here.
If you have a company in Bulgaria, an office address, with a phone number and employee, Portugal will not come and claim that company due to effective management.

And NHR is 20% on foreign income, but 0% on foreign-sourced royalties or dividends, which is where having an offshore holding company comes into play. Cyprus does not have a clear status, malta is also 'grey-listed', so be wary. Portugal will NOT tax you on your Estonian income, even if there is no corporate tax. It's not that you had 'no-tax'. The fact was that you filed taxes in Estonia, they have the right to tax, and it was 0%. But Estonia is not free, because you have to get your money out somehow. This is where Estonia taxes you (20% on disbursing dividends as of right now). Portugal will not double tax you as receiving foreign-sourced dividends are taxed at 0%.

I'm not sure what is meant by "not offering much in return". It's one of the top 5 safest countries in the world and its government and economy work much better and are trending much better than other popular western EU countries. They invest a lot in tech and their people. Spain and Italy are often compared at the same time, and they have the brand name cities, but that's it. The governments and everything are worse off and don't work as well. If this doesn't bother you, go to Southern Italy and take the 90% tax exemption. It's dead simple and the easiest way to get your taxes down to around 5% effectively.

Probably not the most lucid rant here, but there are a lot of comments here about "i don't think" and "i feel like.." that just aren't facts. Find a lawyer or consultant who actually specializes in NHR and saving money through NHR taxation. I guarantee you will find someone who's helped clients with off-shore holdings. Of course, some depends on your citizenship, where you used to live, and how much you want to stay in one place.

What about if I own dividend paying stocks? I am taxed 15% before the money from dividends hit my broker account that means that under NHR this income from dividend paying stocks would be taxed 0% right?

 

[Marc M]

Hello, I born in France but Im living now in Portugal.
Here in Portugal I'm a RNH (Residente Nao Habitual) , its like a special tax advantages for foreigners that become residents in Portugal.
One of the advantages its a exempt taxation in dividends from foreign companies.

What is the problem? That Portugal government could try to say that you are managing the company from Portugal so you have to pay taxes to Portugal.

My situation and plan is this:
I have a digital business that makes 500K per year. This is 100% digital.
I have no office in Portugal, no clients in Portugal, no employees in Portugal.

I want create a Bulgarian Company, hire 2 real bulgarian employees (graphic designer and chat support), they will care the daily tasks of the company.

I will have to pay 10% corporate tax + 5% dividends tax in Bulgaria, then I will bring all the dividends to Portugal with the dividends tax exemption.

I will be paying a 15% effective taxes.

My question and big fear is:

If I have a company in Bulgaria, with employees in Bulgaria, I have no clients, office nor employees in Portugal...can the portuguese government try to make me pay extra taxes just because Im resident here?

PD: I also considered for this same scheme Estonia and Cyprus, but the problem its that dividends dont pay taxes there and Im afraid Portugal will want make me pay 28% dividends taxes.

Thanks for your help guys.

You need a local director, office, 1 employee. Thats it. If a director is missing, contact me. I life there and can make you a reasonable offer