Where to incorporate for cheap banking?

[inector]

A friend of mine has a company in Marshall Islands, doing logistics (nothing shady).

He is considering incorporating somewhere else, because his current bank charges really high transfer fees and regularly asks him to come to the branch.

So he wants a business with low taxes (0-10%), low-cost EMIs, and a good remote physical bank later on (easy application).

BUT these banks should be okay to send money to Marshall Islands.

He lives in a territorial tax country.

Bulgaria?
Hong Kong?
Singapore?

 

[JohnLocke]

I believe @Don or @CyprusLawyer101 @CyprusBusiness and @CyprusLaw can help you out with real solutions for your problem.

 

[CyprusLawyer101]

A friend of mine has a company in Marshall Islands, doing logistics (nothing shady).

He is considering incorporating somewhere else, because his current bank charges really high transfer fees and regularly asks him to come to the branch.

So he wants a business with low taxes (0-10%), low-cost EMIs, and a good remote physical bank later on (easy application).

BUT these banks should be okay to send money to Marshall Islands.

He lives in a territorial tax country.

Bulgaria?
Hong Kong?
Singapore?

I see potential for some good structuring opportunity involving a CY co and his tax residency

 

[uplana]

I see potential for some good structuring opportunity involving a CY co and his tax residency

What would you suggest, some more information on what you see?

 

[Don]

A friend of mine has a company in Marshall Islands, doing logistics (nothing shady).

He is considering incorporating somewhere else, because his current bank charges really high transfer fees and regularly asks him to come to the branch.

So he wants a business with low taxes (0-10%), low-cost EMIs, and a good remote physical bank later on (easy application).

BUT these banks should be okay to send money to Marshall Islands.

He lives in a territorial tax country.

Bulgaria?
Hong Kong?
Singapore?

First, cheap EMI-s you mostly find in the EU or UK.
Marshall Islands could also get an EMI account, but it's not cheap.

Estonian residency + Estonian company with a branch office in Bulgaria can be a decent choice, and in some cases, even close to zero tax structure.
Especially if he qualifies for the CIT exemption.

1) on the Estonian level, there is no tax before profit distribution and no WHT, and combined with Estonian tax residency, the total tax is 0% if redistributing branch profits to yourself on Estonian level
2) Bulgarian branch - profit tax is by default 10%, but if you operate in an area with high unemployment, you get a 100% exemption from CIT. It applies to taxable persons that carry out production activities. If a municipality is no longer included in the list as a result of increased employment, the taxable person can retain the right to tax relief for a period of 5 years from the year in which the municipality was excluded from the list.

 

[inector]

Estonian residency + Estonian company with a branch office in Bulgaria

Always a great choice

if you operate in an area with high unemployment, you get a 100% exemption from CIT. It applies to taxable persons that carry out production activities

Interesting, didn't know that

Bulgarian branch

Considering Bulgaria is part of FATF and he has a lot of transfers to offshore, like Marshall Islands and Belize, do banks run more checks at the moment?

 

[12345]

usa llc

 

[Don]

usa llc

Probably best for transacting with marshall islands

 

[inector]

usa llc

Forgot to mention, his nationality is 3rd world and it's not welcome in USA (it's not Russia / Ukraine)

US has no non-resident physical banks and he can only apply for Mercury.

Estonian residency + Estonian company

No office to pick e-residency near him. He won't travel also.

I see potential for some good structuring opportunity involving a CY co and his tax residency

He tried Cyprus in the past, and he didn't like it (personal preference I guess)
-
P.S. Not trying to be mean about propositions, just that it's a complex use-case.
Bulgaria so far is a good choice, open for more.

 

[Clearsky Network]

A friend of mine has a company in Marshall Islands, doing logistics (nothing shady).

He is considering incorporating somewhere else, because his current bank charges really high transfer fees and regularly asks him to come to the branch.

So he wants a business with low taxes (0-10%), low-cost EMIs, and a good remote physical bank later on (easy application).

BUT these banks should be okay to send money to Marshall Islands.

He lives in a territorial tax country.

Bulgaria?
Hong Kong?
Singapore?

I wouldnt choose Bulgaria at the moment as its under EDD and many EMIs may decline the company only because of the jurisdiction.
HK ans Singapore are great, but considered to be offshore for EMIs, therefore the pricing may be high.
Cyprus can be a good choice like recommended below.

 

[Propeller]

1) on the Estonian level, there is no tax before profit distribution and no WHT, and combined with Estonian tax residency, the total tax is 0% if redistributing branch profits to yourself on Estonian level

So, you're telling me you can start a business in Estonia, make money, and not pay any taxes? That doesn't sound right. How much corporate tax does a regular business actually have to pay?

 

[Don]

So, you're telling me you can start a business in Estonia, make money, and not pay any taxes? That doesn't sound right. How much corporate tax does a regular business actually have to pay?

All undistributed corporate profits are tax exempt.
Distributed profits are generally subject to the 20% CIT at 20/80 of the net amount of profit distribution.

However, dividends distributed by Estonian companies are exempt from CIT if the distributions are paid out of:

• dividends received from Estonian, EU, European Economic Area (EEA), and Swiss tax resident companies (except tax haven companies) in which the Estonian company has at least a 10% shareholding profits attributable to a PE in the European Union, European Economic Area, or Switzerland
• dividends received from all other foreign companies in which the Estonian company (except tax haven companies) has at least a 10% shareholding, provided that either the underlying profits have been subject to foreign tax or if foreign income tax was withheld from dividends received, or
• profits attributable to a foreign PE in all other countries, provided that such profits have been subject to tax in the country of the PE.

 

[Propeller]

A simple LTD in Estonia pays 20% corporate tax right?

 

[Don]

A simple LTD in Estonia pays 20% corporate tax right?

yes, on distributed profits.

 

[Cavendish]

All undistributed corporate profits are tax exempt.
Distributed profits are generally subject to the 20% CIT at 20/80 of the net amount of profit distribution.

However, dividends distributed by Estonian companies are exempt from CIT if the distributions are paid out of:

• dividends received from Estonian, EU, European Economic Area (EEA), and Swiss tax resident companies (except tax haven companies) in which the Estonian company has at least a 10% shareholding profits attributable to a PE in the European Union, European Economic Area, or Switzerland
• dividends received from all other foreign companies in which the Estonian company (except tax haven companies) has at least a 10% shareholding, provided that either the underlying profits have been subject to foreign tax or if foreign income tax was withheld from dividends received, or
• profits attributable to a foreign PE in all other countries, provided that such profits have been subject to tax in the country of the PE.

Hi Don, I have been researching an Estonian Company and e-residency over the past few months and was intrigued about the 0% CT on undistributed profits. However as I am an unlucky UK resident and enjoying the pleasure of world-wide taxation does that bin the Estonia concept, as I will own / control the company? Would appreciate your insight thanks.

 

[JohnLocke]

Maybe you guys should get back on topic and what OP is asking for? You may open a new thread with your questions.

 

[Cavendish]

Maybe you guys should get back on topic and what OP is asking for? You may open a new thread with your questions.

Noted.

 

[aage]

usa llc

If it's still possible to open a Mercury bank account there, yes. If not I would look into a UK LTD with Wise account.