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Best country / setup to minimize tax? (software biz, ~400k, eu)

You could qualify under the CY IP regime. A cyptue company could be your.solution.
Thank you very much.

I think that with the nature of this business (mostly passive income) you can set up anywhere with no tax or low tax and just live in Thailand or Malaysia.

A combination of UAE + residence in one of the aforementioned countries could work well.
This is a bit of a segway, but I actually stayed in Thailand for some time before and I liked it, so I am looking at that as well.

If I stay there, do I actually need a company? The companies which send me payouts (such as Paddle) can pay me directly to my personal Revolut account (Lithuanian). Would that work for me to have 0 tax legally as long as I do not bring the money into Thailand? (I'd just send it to a broker). Is that completely solid? is there any risk in the future if I move that money, that the broker / bank / new country would ask me about proof of tax paid on it?

Not sure I want to move away from Europe + I have some property here, but I want to understand what my best options are. I suppose with Cyprus advantages are that I'd get to stay in Europe + have all the money completely in the clear.
 
Thank you very much.


This is a bit of a segway, but I actually stayed in Thailand for some time before and I liked it, so I am looking at that as well.

If I stay there, do I actually need a company? The companies which send me payouts (such as Paddle) can pay me directly to my personal Revolut account (Lithuanian). Would that work for me to have 0 tax legally as long as I do not bring the money into Thailand? (I'd just send it to a broker). Is that completely solid? is there any risk in the future if I move that money, that the broker / bank / new country would ask me about proof of tax paid on it?

I think that's a bit risky. At some point one of the EU countries with which you are involved could make some sort of claim.

In my opinion, setting up a company is the right way to do it, especially for your income level, and to have "all money in the clear" like you stated.
 
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Maybe just set up a holding company for the time being to get rid of the WHT of 8%.
Then, the structure would be just 3% +- 1% tax.


Times have changed regarding the automatic exchange of information between financial authorities. In practice, this means you shall have substance. Also, banking is increasingly complicated.

It depends on how much income you need to live.
Some people are happy with 40k net income per year in Slovenia while having a company abroad.
Sole proprietor with normalized expenses -> they assume your expenses are 80% of your income, and they tax you 20% on the remaining 20%, so effectively 4% tax (a bit more if you make more than 50.000€). This is basically what all IT freelancers do.


As mentioned above, you could start by setting up a holding company in an EU jurisdiction for zero WHT on dividends.

Estonia could be quite a cost-efficient choice for such a simple holding company.

You distribute dividends to the holding and can redistribute those profits to yourself later without further tax, depending on where you will be a resident.
Having this in mind, Estonia presents a decent proposal since such dividends sourced from Romania would not be taxed if distributed to Estonian tax residents from the Estonian resident holding company, and getting Estonian tax residence is simple. It does not require a physical presence in the country, but you must register your address in the population register.
Alternatively, you can consider other jurisdictions for personal tax residence that would not tax such dividends.

On top of that, you will get access to 0% tax until the distribution regime + some other potential structures that could be interesting going forward, like:
  • Estonia-Malta fiscal unit structure (effective tax 5%)
  • Estonia-Georgia Virtual Zone company with Estonian tax residence (effective tax 5%)
  • Estonia-Bulgaria/Hungary/Switzerland (effective tax ~10%-11)
  • Payout salary from the Estonian company while being a tax resident in UAE (0% tax)
and more...
Well in Estonia if you payout a salary, yes is not taxed as the dividends, but you still have to pay Income Tax and Social Security Tax no?
 
It usually works that way in most countries (if not all), anything else is a misunderstanding or perhaps the sender means something else.
You usually pay tax and social contributions where you are resident. For Europe there are some rules on social contributions which limit the payments to exactly one country at a time. Under certain conditions it may not be the residence but the workplace.

The problem he will have us that you cannot have a company making 500k and paying it all as salary. A company is meant to be profitable and the salary needs to be at a fair market value and in relation to the revenue. Hence you will have to take it something as dividends eventually.
 
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Not if you have requested a tax ruling beforehand.
In theory yes, in practice no due to a fact that ruling is based on Your description of the problem. So in very simple cases true, it will give You some protection - but in those kind of cases You actually dont need the ruling. In a bit more complicated cases common practice there, by the tax authorities, is to assess the case in Your disfavour even if You can prove them wrong, or deny the previous ruling stating that Your description of the problem was not detailed enough. In the end You will win in court but a) this will take years as polish courts work really slow b) will cost You money. And since few years PL tax authorities, if everything else fails, have a tendency to use a new "weapon" they got - so called "law circumvention clause" which basically gives them the right to classify broad spectrum of actions ( including legal one ) as illegal - "inconsistent with the spirit of the Act"
 
What should be a "law circumvention"? It is just called abiding by the law. If they do not like it, they have to change the laws. But hey guys, I think all empires raised taxes shortly before their collapse. It is normal.
 
What should be a "law circumvention"? It is just called abiding by the law. If they do not like it, they have to change the laws. But hey guys, I think all empires raised taxes shortly before their collapse. It is normal.
Using the law that they don't profit from as much instead of the law that maximises the profit earned by the government's coercion.

But look at the Polish leaders. Tusk is Putin's friend, and he publicly announces that Polish law is what he thinks it is, not what is said in the legislation.
 
Buy an apartment in Bahrain (minimum 120k eur), you get a 10 years renewable residency there (0% personal basically no taxes at all).

Then use a Hong Kong Company, if you manage to get the offshore status you pay 0% on the company as well.


Perks:
- no stay requirement in bahrain, you can live anywhere
- you can rent out the apartment in bahrain for some extra returns
Hi, can I ask you to share please where did you see that you can have a 10 years residency visa with jus 120k eur of real estate investment?

Is not 200k bhd the minimum amount to invest in Bahrain to obtain that 10 years resident visa?
 
Thank you very much.


This is a bit of a segway, but I actually stayed in Thailand for some time before and I liked it, so I am looking at that as well.

If I stay there, do I actually need a company? The companies which send me payouts (such as Paddle) can pay me directly to my personal Revolut account (Lithuanian). Would that work for me to have 0 tax legally as long as I do not bring the money into Thailand? (I'd just send it to a broker). Is that completely solid? is there any risk in the future if I move that money, that the broker / bank / new country would ask me about proof of tax paid on it?

Not sure I want to move away from Europe + I have some property here, but I want to understand what my best options are. I suppose with Cyprus advantages are that I'd get to stay in Europe + have all the money completely in the clear.
With no company, you can have 0% personal income tax in Dubai.
 
Hi, can I ask you to share please where did you see that you can have a 10 years residency visa with jus 120k eur of real estate investment?

Is not 200k bhd the minimum amount to invest in Bahrain to obtain that 10 years resident visa?
It's 2 different options, unfortunately it's quite badly advertised, but for 200K BHD you can have the golden visa, and for 50K you can get a Self Sponsor Property Owner visa.

The only difference is that with the Golden Visa you are allowed to work in the country.

You can actually see and request the Property Owner Visa from Bahrain Electronic Visa Service

This is the whole process: