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#21
macthaiver said:
...they don't accept malta invoice they want to pay the crazy tax in Holland even if the project is 3 months.. same in Germany...
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Indeed, a number of EU states are quite aggressive in regards to the use of overseas invoicing companies.

You can still pay all personal taxes in Malta on the income you earn from your projects in the Netherlands or Germany, but this requires a social security (A1, formerly e101) certificate from Malta. And you only get this A1 certificate from Malta if you have a track record of making social security contributions in Malta.

There are rumors of Bulgaria handing out those A1 certificates without proper due diligence. Primarily abused by firms who appoint temporary construction workers across the EU. For the issuing state, every A1 certificate they issue entitles them to tax revenue, even if not much, it's better than nothing. If you want to reduce tax burden, look around for easy opportunities to fetch that A1 certificate from a low tax member state. With A1 certificate, you can work for up to 2 years in another EU country while paying all personal taxes in your "home country".
 
#22
That's Great!! Home country will be my citizenship country or the Tax residence country?? Because if is the first (citizen) leave it.. its very high :).. if its the Tax residence country, how i can work in another country and keep the 183 days in the Tax R country then? I will be thrown out.
 
#23
macthaiver said:
That's Great!! Home country will be my citizenship country or the Tax residence country?? Because if is the first (citizen) leave it.. its very high :).. if its the Tax residence country, how i can work in another country and keep the 183 days in the Tax R country then? I will be thrown out.
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I don't think you fully understood. Nobody will "throw you out".

If you live in Malta and pay social security taxes there, you can apply for what is called an A1 certificate for your temporary assignments abroad. They will be more than happy to give you one. In the EU, an A1 social security certificate is essentially an equivalent to a tax residency certificate. During the validity period of your A1 certificate, your tax residency in Malta is recognized all across the EU, even if you spend 0 days in Malta.

This document shows a degree of commitment to one member state. If you tell the Netherlands or Germany that your intention is to permanently relocate there, they will ask for local taxes from the first day you arrive. With A1, Malta will accept you back and consider you a resident, don't worry about it :)
 
#24
Understand.. Great,., the questions come now to;..

If you are CITIZEN of Italy, and TAX resident & resident of MALTA, and you move to work to ITALY (back to your citizen country) will this be working ? :)

Good question eh ? :)
 
#25
macthaiver said:
Understand.. Great,., the questions come now to;..
If you are CITIZEN of Italy, and TAX resident & resident of MALTA, and you move to work to ITALY (back to your citizen country) will this be working ? :)
Good question eh ? :)
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A Good question because you know I can't possibly answer this one with a degree of certainty ;)

Temporary assignments abroad are covered by EU directives, and by law, it would be completely acceptable to tip your nose back in Italy, even work there for a while. However, under such a scenario, Italy could rightfully consider it an intentional abuse.

I'll give you two edges of the argument.

1) You're absolutely fine if you can prove (to Italy) that you have worked for other clients in other countries, at least 2 years have passed since you left, and you can show at least 2 income tax returns from Malta.
2) You're certainly in trouble if you cannot prove that you have worked for other clients in other countries, furthermore, you come back as a Maltese working for your previous Italian employer; very little time has passed since you left, and you have not yet paid any taxes in Malta.
 
#27
macthaiver said:
is it ok with the Marsall company?
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LOL no awe¤""%awe¤""%

With a Marshall Islands company you can wipe a*s these days.

Maybe you can enter into a contract with a non-reputable, irrelevant EU company in an irrelevant business sector. If you want to enter a contract with a reputable EU client, or with any client in a regulated sector where clients pay well, i.e. medicine, insurance or banking, you will hit a stone wall. Nobody will accept you. Auditors, regulators and tax officials would torture them even during their sleep. Needless to say, payments and remittances in such a relationship would be a nightmare.
 
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#29
macthaiver said:
Ah, which then? the cheapest option, no audits, no files etc.. the cheapest...
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If you want to do business in EU, you should stick with EU options. Alternatively, consider a non-EU country that has DTA agreements with the EU states where your primary clients are.

Why?

I've used Gibraltar companies for various puroses. Gibraltar is a full member of EUEA and has quite stringent incorporation criteria. Furthermore, I have a real office and employees. On numerous cases, I've had to re-arrange my contracts and banking affairs because of counter-party "de risking". If this can happen with a company registered in EUEA, then what purpose does a company registered in a [zero tax/no reporting/no audit/no incorporation criteria] non-EUEA country serve? A company you described is OK for passive holdings, or perhaps for doing business in central Africa, but it will certainly not work for any service-based hustle in the EU. Bring your expectations lower.
 
#31
macthaiver said:
but can work with Malta to invoice malta existing companies ....
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Perhaps a small company in an unregulated sector is fine with it. I'm not predicting it will go as so smooth if you want to do a bit of work for a Maltese bank.

With that said, if you believe there are opportunities for your Marshall Islands IBC out there, it makes sense to keep it in your pocket. When you close a contract, sign on behalf of that IBC first. If the client gets paranoid, offer a cleaner alternative.
 
#33
macthaiver said:
no i mean to work with my own malta company... customer > malta > marshal..
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Alright then, but this opens up a whole new set of issues to consider. You want to make the Marshall islands company 100% owner of the Malta company, and drain the Maltese company of taxable income you earn in the EU, correct?

It will cost at least 50K euros annually to make the Marshall Islands company substantiated to a point where the Maltese tax authorities will give you an advance ruling and approve some kind of a mildly aggressive tax structure we can put together. The arms-length principle greatly limits what can and can not be done, effectively reducing the tax savings. And then, on personal level, which makes up the majority of burden, you still pay taxes in Malta.

Pointless. I see no worthwhile benefit in that holding + op.co structure unless you want to go wild and not declare your corporate earnings to the Maltese tax authority.

Bye for today, back tomorrow! thu&¤#
 
#34
what is the op.co structure?
No i dont say to make the marshall owns the malta.. Nothing! just invoicing the services through marshall. Customer buys from Malta, and malta buys from Marshall.. thats' it

Thank you so much @xzars
 
#35
@macthaiver as I already told you and xzsar confirmed, using a jurisdiction like Seychelles, Marshall, Belize or whatever would cost you a lot of money to build a structure which is accepted by the EU tax authorities. Because just the registered agent address is not enough. The tax authorities also know the most offices the online offshore providers sell you, they have a database for wellknown nominees and office adresses. So they can immediately deny your "substance appeal". Always remember that the EU members are quite well connected.
So better choose a country which is not on this list: http://www.europarl.europa.eu/cmsda...621872-Listing-tax-havens-by-the-EU-FINAL.PDF

That's why I recommended the US. They are a G7,G8, G20 and whatever member, they have international power and for diplomatic reasons they won't be seen as offshore jurisdiction by the EU. Most tax authorities I had to deal with never saw big problems in US invoices (if minded the arms-length principle, of course!). They sometimes wanted to see a proof of the service but that's mostly it. If your IT knowledge is very good then you should always be able to show something. Just show them some code, some ESXi setups, dockers, whatever and they are fine. Also mind to show a small history of some emails like "offer-->offer accepted-->delivery-->payment" .
 
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#38
neweraoffshore said:
You will run into problems with a Seychelles company if you don't spend a lot of money on an infrastructure to get payments to your seychelle company. Seychelles is on the OECD watchlist and therefore the EU taxman is allowed to decline the invoice from the Seychelles company and you may have to pay full tax on the amount. You will also run into big problems when being audited when doing business with countries like Seychelles, Belize,etc. They are not stupid, they know what's going on.
Maybe you want to read about the offshore problems here: [FOR EU CITIZENS] Problems when going Offshore - List

However, if you are not an EU passport holder a Seychelles company may be a good option. So it would be nice to tell us the country where you are taxed in.
Seychelles at "end haven" is good even for EU passport holders, however as told before you need to spend some money on an infrastructure to get money to your end haven without running into problems with your tax authority.

In my opinion, the US is the best offshore jurisdiction in the moment. A lot of forum member also like Georgia. However I am a little bit cautios with Georgia as they are quite new in the offshore market and I fear that something like in cyprus will happen there, but this time without EU bailout.
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Really? The US? With which payment gateway/provider? thank you
 
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