Recent content by Don

It is also an option for the shareholders to inject the capital directly into PE in the first place. In such a case, there is no "deemed distribution," as assets are not taken out from the Estonian headquarters. Deemed distribution is a crucial concept for anyone managing an Estonian company to...

Yes the head office can finance a foreign PE, but when moving assets to a foreign PE it is usually deemed as distribution, unless assets are returned within 12 months.

Yes you need it for accounting, to keep things separate. Its really simple to do with a broker like IBKR.

You will always need to understand the national laws of the state, but noone has time to study the law of each state. It can get quite complex sometimes as structures and types of income might be treated differently across jurisdictions, so international tax advice is often provided in...

IBFD also provides online courses and useful webinars (paid). Just to name a few titles if one wants to study specific topics: Substance requirements in post-BEPS international tax planning Effective international tax dispute resolution PE Risks and Opportunities in International Tax...

What makes you think this is going to happen? And if, when?

Africa is quite diverse. Im quite ignorant on the possibilities, but Chad and Seychelles seem rather different to put them in one basket. The latter was quite relaxed place during COVID lockdowns.

Yes. If needed you will be asked to show the tax declaration of the PE, to prove that the repatriated income was sourced from abroad. It works similarly as other jurisdictions which don't tax foreign sourced income like Singapore, Gibraltar or Malta.

I believe you mean ID card, not passport.

The thing with Estonia and ATAD is that even if the foreign profits are attributed to the Estonian holding due to being qualified as a non genuine arrangement due to lack of substance, the profits would still not taxed until the distribution actually happens. Always best to have some substance...

Estonia will not even check how much tax is paid in Cyprus. They only want to know how much profit was repatriated, as this will be tax free in Estonia. So far, EU member states have not reached an agreement on the highly controversial Atad 3 draft directive proposal and the final outcome is...

No, its mostly capital gains from trading shares in all types of companies that are exempt in CY. Not all securities are exempt or commodity derivatives. Thats why this Estonia - Cyprus structure can be great as if you trade multiple types of instruments, those trades that might be taxable in...

The rate of tax on Cyprus branch profits / PE profits is the same as on corporate profits (12.5%). No further tax is withheld on transfers of profits or funds to a foreign head office. Based on DTA, business profits from a foreign PE are normally not double taxed in Malta. Its not automatic...

For the sake of completion you can also operate as a Cyprus PE. Persons that may benefit from the Cyprus tax regime include Cyprus tax-resident taxpayers, tax-resident permanent establishments (PEs) of non-tax resident persons, and foreign PEs that are subject to tax in Cyprus.

Yes, obtaining residency can be a great way to get access to banking and build up credit. It is possible in some cases to become a legal resident without turning into tax resident. Thats not entirely correct. You could also operate as a branch office of a foreign company in Cyprus. There is no...