Recent content by anticfc

Following up on the Sub-year offshore company, I present the accrued deficit CFC company. Similarly to how profits have different values based on the CIT in a given country, so does accrued deficits. When a company becomes a CFC company for a given owner, some accrued deficits might be taken...

Yes I was thinking of something along these lines, but that requires being allowed to hold foreign assets. I see countries where owning foreign currency is simply not allowed, but I don't understand how business can avoid owning either foreign shares or foreign currency. In mirror trading, at...

How are the financial markets used? A complex setup would be a set of companies, inside and outside the country in order to generate invoices. Seems risky and expensive though. Can they buy stakes in foreign companies that suddenly go bankrupt? How can a Chinese company buy stocks in a...

A lot of countries have currency restrictions, including countries like China. We know that smart money is leaving China and will stay in USD for example (or CHF), but how do people get money out? Currency restrictions like this exist in many countries all over the globe. For example, assume...

You should read up on lean business practices. Don't spend a lot of time on payment systems before you have validated your business plan.

A robust, long-term solution is an anti-CFC setup where ownership is split between people of various jurisdictions. As you are into crypto, you probably understand how this can be done securely using the blockchain.

You can always get around CFC rules by owning a minority stake in the company. How minor depends on the jurisdiction. You just have to manage the arising trust issues.

@Honest Junior I'm working on compiling an overview of CFC rules - focusing on high-tax EU countries. But there's also management & control to consider. If the company is operated from your jurisdiction, then it will have to pay taxes there. One option that I think hasn't been discussed...

I see a lot of CFC laws that in order to simplify the definition of ownership, defines ownership at the end of the tax year only. This is interesting as it seems CIT of 0% is then possible by simply not owning the company at the end of the year. This creates dividends or capital gains that...

There's still management & control trickery involved.

The labuan company would be tax resident in Norway (assuming the OP was living in Norway). Though the CFC rules in Norway disregards any ownership during the year, so if you remove the CFC company before end of year (and re-create another one the next year), then it's not CFC - assuming you can...

You're already living in one of the most beneficial jurisdictions in Europe. The taxes are the lowest of northern Europe, and the deductions are the highest. It's fairly easy to get a tax rate close to, or less than 0% in your situation.

Do you know what the structure looked like?

What's the capital tax where you live? If that tax is OK with you, and assuming you are subject to CFC rules, then an option could be a CFC-pool, a partnership with other freelancers. That could possibly keep costs down.

If you want to do it by the book, then 1. Transfer ownership of your company (Y Inc) to your friend's company (F Inc). You can write this on a piece of paper. 2. Write a agreement between you and Y to make your loan freely transferable (if it isn't). Another piece of paper. 3. Pay dividends...