Offshore foundations in EU/EEA

[Jerry1911]

Simple question: are offshore foundations such as Panama, Belize, Seychelles, etc. recognized in EU/EEA?

For example, is it possible for an EU company (an Estonian OU for example) to be owned by a foundation registered in one of those countries?

 

[JustAnotherNomad]

I am not a lawyer, but to the best of my knowledge:
Yes, it is typically possible for a European company to be owned by a foundation registered in one of those countries. They are typically recognized as entities of their own for such purposes.
But when it comes to tax, it's a completely different story. If you're tax resident in the EU, the tax authorities will typically "look through" the foundation if it's registered outside of Europe. So if you're the beneficiary of the foundation, then they will tax dividends paid from an EU company as if you had received the money directly.
If there's a claim, such as during a divorce, I would also expect an EU court to ignore the foundation.
There's a lot of stuff to be aware of, you cannot be in control of the foundation, and the management of the foundation must not release funds if they find you are being pressured (there's a specific term for this which I can't remember).
The "correct" way to do this if you're involved with the EU, is to use a Liechtenstein foundation, as Liechtenstein foundations are recognized by the EU, but since they're not an EU member, they have strategic advantages.
But they're not cheap (10-15k per year in running costs) and you'll really want to use a good lawyer to set everything up, as tiny details can render the whole structure useless.

 

[uplana]

It doesn't matter if it is or not, if you setup a structure like that you want to have a tax lawyer in place to help you, because you should more or less expect the tax man to knock on your door.

 

[Jerry1911]

So...UAE foundations make sense when combined with UAE residency. Panamese foundations make sense when you live in Panama. And Liechteinstein/Austrian/Maltese(?) foundations are usually combined with EU/EEA residency.

But what about Seychelles, Belize, Malta, Isle of Man, Guernsey, etc.? People who set those up, where do they live? Any practical info on this topic?

I would also love to know what kind of structures residents of Andorra usually set up.