Recent content by lacomaco

Are they swiping your passport or ID? If not then they just which is not a problem at all as records are not registered

In a Double-tax treaties several types of income can be taxed in both countries, foe example dividends This termination affects US taxpayers much more than Hungarians as the US obviously has much more investment in Hungary than vice versa… Quite surprisingly this “tax expert” does not even...

Pm me pls

No, I am just cautious

Servers are in The Netherlands, webhosting is done in The Netherlands, VPS sare running on servers located in The Netherlands, the servers which are sold are in The Netherlands and clients are also from The Netherlands. Let's say that the possibility of taxation of the PE in The Netherlands is...

The country where a foreign registered company is controlled and managed from may tax the profits of the company. Control and management can be a “permanent establishment” - the PE.

When someone indicates “ will the profits be tax-free?” I always look both at the corporate and personal tax levels. If you start your trading after you physically move to Cyprus then the PE will not be a question. If not (and according to my experience ”eventually” usually means later) then my...

The US, Canada and Australia will not be too much different

It is just so funny to hear the ravings about blockchain forgetting to tell that recording all transactions on the chain could also have some bad consequences…. Like the people who donated to the truck drivers in Canada and not just their bank accounts but the crypto accounts were frozen…...

If I understand your question correctly then I need to respectfully decline commenting on what CyprusLaw wrote. What I referred to was the possibility of taxation of the Cyprus company’s profits in the country of your residence through the place of business rule

You forgot to attach the first rule in the OECD model treaty Paragraph 5: 1. For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. That is why Rule 2 says “especially”...

What if you try to change your way of thinking Sergey and put substance behind what earns you the money? Cheap solutions bring cheap results

Do not forget to ask for accounting and auditing cost, especially if transactions are done in several currencies. Also, check if you might have a place of business via controlling the activities in your home country

Yes you need substance, a flexi desk is not a substance

Do you think that any respectable person can answer the question of how much the expected audit fees will be in 2025? If that was your question