Recent content by cyprustoomuch

Since switzerland has this annyoing "Verrechnungssteuer" on paid dividends to the mother company. Would you rather recommend a foreign subsidiary of a CY company that just registers a PE in Switzerland, or would you setup a new Swiss GmbH as a daughter of a CY Company? The PE certainly has...

Thinking about switzerland myself for next year and had the same discussion. To avoid unnecessary tax and social insurance payments in switzerland my tax advisor for switzerland also recommended me such a solution. Depends where you live right now. Easiest case would be if you already have tax...

I did some quick checks last week as well. The easiest path to get a residency should be the 50k usd investment entrepreneur visa. All the other stuff looks like a real pain to even read through.

They have a DTT, so what you say is pretty much nonsense. In whatever country I have stronger connections with gets the right of taxation. Renting some airbnb for 4 months in spain meanwhile having a fully equipped home in cyprus clears the case. Please read properly before answering such...

Are you trying to say that a 4 month residency in spain, that is directly afterwards interrupted without any further available property should lead to a center of someones personal life? Explain me please where the center of interests should come from, because leaving the country and quitting...

Thanks for your reply. Please stick to my special case. There is a full year permanent house in Cyprus in which I have already spend 4 months this year. Then there is a limited rental contract for 4-5 months in Spain for example. After that I am leaving the country again and the residence ends...

Just trying to enjoy life and see some new places for a longer time than just 2 weeks of vacation, cyprus can get boring actually when you spend there too much time. We have a car packed with all our basic stuff and can just travel around europe a bit

I have a tax residency in Cyprus where I also stayed for the past 2 years completely but somehow want to use the 60-90 Day minimum there and spend more time travelling in other EU countries without exceeding there any duration above 5 months. Is there a chance to do so in southern european...

Hello, Spain and France dont consider you tax resident if you have no permanent home, so if somebody would just rent a house for 5 months he wouldnt be considered a tax resident. Now lets assume that person is working on a daily basis from his airbnb in spain in his online business which is...

Hey @ironhide I am looking at andorra residency + a local company and additionally a 0% CIT offshore company too. How relaxed is andorra about offshore companies and what are their general substance requirements abroad? I would be interested in an US LLC, do you know how they tread indistributed...

Okay but BE and Lux dont even consider you a tax resident when you are less than 6 months there and have another tax residency. So the PE can also easily be assumed in his other country of residence. He could live in Bahamas or UAE for 6 months and have his office there, have enough substance...

The goal is to have an offshore company structured in some way to not trigger a PE, question is just what requirements Lux, BE, AU and CH have for this in detail.

To what tax trick are you referring here? I know that germany allows tax detuctions when you bring in a company from abroad into germany and that way can write off the full company value (13.7x annual profit) over a period of 10 years I guess. Is it that what you mean? CFC is in luxembourg not...

What do you mean by their tax code? What is that? Germany will not allow you this when you still have control over the bank account and just 2 or 3 indians working there. Yes sure, the main goal is to live in a high quality country and yet achieve a stress free 0% corporate tax. I am in...

Explain me please how andorra is tax free. They have a 10% corporate tax that can be avoided by using an offshore company but income will be taxed at 10% too. Andorra is also a very good choice in europe.