Recent content by Lateraltrust

Yes absolutely, you can redeem a part of your capital . This will be materialized by the buying back and cancelation of the company own's shares. You will absorb the corresponding portion of profit to Jersey free of withholding tax. This was confirmed by caselaw un november 2017. Hybrids are...

If you want to cross on foot, why would you like to come back by plane ? It does not make a lot of sens to cross on foot to avoid Covid restrictions and to come back by place, because you will likely be subject to the PCR test you tried to avoid

By reference to the arm's length principle following the rules provided by art 57 cgi. This is also confirmed in art 6 of the tax treaty according to which where an economic activity is carried out by an establishment located in another state, this establishment should pay taxes based on the...

You can be a direct shareholder and will not fall in the scope of the anti abuse rule of article 123bis with Bulgaria, but not director. This has to be delegated to local people to not raise the FISC's attention. If you are director and manage actually from France this company, you will be a...

First, the fact that one of your company will be shareholder of the Bulgarian company instead of you is irrelevant as CFC targets direct and indirect control. However french CFC rules are not applicable with Bulgarie as EU member states. The substance evidence depends on the activity. In...