There a couple of countries that offer tax benefits to HNWI who don't work in the country, like Switzerland, Italy, Greece etc., or even the UK.
A requirement of these programs is typically that you can't work in the country (or if you do, then tax benefits don't apply to that income).
Even if you had substance in another country, e.g. a company with some employees in Malta or the UAE, they would still tax you if you are actively involved in the business from your new home.
But I had an interesting idea the other day, and I believe this is actually something a lot of people do:
You can set up a company in Liechtenstein, where the corporate tax rate is 12.5%.
And then you live in Switzerland, but you commute to your Liechtenstein office (could be a desk in a co-working space) and only work from there. (I have heard that the Swiss tax office really checks this and demands to see receipts etc.)
Interestingly, the CH-LI DTA specifies that for cross-border commuters, income from the other country is only taxable where you live. So if you live in CH, but work in LI, you don't pay tax on your salary in LI, but in CH.
And as for dividends, there is no WHT. Liechtenstein generally doesn't levy any WHT, but even if this should change in the future, the DTA contains a 0% WHT parent-subsidiary directive.
Now ordinarily, as far as I know, dividends are taxed as income in Switzerland.
However, let's say you're under lump sum taxation. Then there is only the lump sum tax and you aren't taxed on foreign-source income.
If this is true, then shouldn't both the LI salary and the dividends be exempt from taxation in Switzerland? So you would only pay the lump sum and that's it? Or is there something I'm missing?
Do you know of any similar setups? I've only seen Monaco discussed so far, where people say that PE laws generally aren't enforced.
A requirement of these programs is typically that you can't work in the country (or if you do, then tax benefits don't apply to that income).
Even if you had substance in another country, e.g. a company with some employees in Malta or the UAE, they would still tax you if you are actively involved in the business from your new home.
But I had an interesting idea the other day, and I believe this is actually something a lot of people do:
You can set up a company in Liechtenstein, where the corporate tax rate is 12.5%.
And then you live in Switzerland, but you commute to your Liechtenstein office (could be a desk in a co-working space) and only work from there. (I have heard that the Swiss tax office really checks this and demands to see receipts etc.)
Interestingly, the CH-LI DTA specifies that for cross-border commuters, income from the other country is only taxable where you live. So if you live in CH, but work in LI, you don't pay tax on your salary in LI, but in CH.
And as for dividends, there is no WHT. Liechtenstein generally doesn't levy any WHT, but even if this should change in the future, the DTA contains a 0% WHT parent-subsidiary directive.
Now ordinarily, as far as I know, dividends are taxed as income in Switzerland.
However, let's say you're under lump sum taxation. Then there is only the lump sum tax and you aren't taxed on foreign-source income.
If this is true, then shouldn't both the LI salary and the dividends be exempt from taxation in Switzerland? So you would only pay the lump sum and that's it? Or is there something I'm missing?
Do you know of any similar setups? I've only seen Monaco discussed so far, where people say that PE laws generally aren't enforced.
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