Recent content by lokifree

Thanks! The Client specifically wants the UK company (personal wish). And at some point I said yes let's do it as I wasn't envisaging the given proven with the Swiss bank account. Who knows, maybe it makes more sense to drop the idea now....

I've recently opened a personal holding LLC company for the EU client in the UK. We knew that bank account could be the issue but client had a relationship with a Swiss bank (personal account) so we thought (as it normally happens) that opening a corporate account with a Swiss private banking...

Hi Karolina my experiences with Cyprus is that it’s hard to do things yourself. I can give you contact details to few accounting firms. Most of them as you pointed out have a standard pricing list but are also open to discuss the customized offer if you describe them well your business and you...

Can you explain what sort of income will accrue in the UK company? It matters for the determination whether Portuguese CFC rules apply. BRIEFLY ABOUT CFCR RULES IN PORTUGAL: Controlled Foreign Company Rules (CFC Rules) To be subject to the Portuguese CFC rules, the following criteria apply...

I can't tell you for sure about the other countries, but in my home country (Poland) they will chase you and you could (not necessarily would) be considered a criminal if you fail to pay. Ofc the amount is small and we're talking about income tax and not VAT (which is at spotlight) so the...

it doesn't matter really. Cyprus has a lower CIT rate than Portugal (21%) and it suffices to apply CFC rules on the difference. However, it largerly depends what is the source of income of such company. If it is capital gains or dividends, both Cyprus and Portugal apply tax exemption (under...

I guess Cyprus as well, but then you may face CFC problems in Portugal due to a low tax rate in Cyprus. With Malta (35% nominal tax on corporate income) and their tax refund machanism you can still avoid CFC issues as far as I know.

Then John may become a fiscal criminal and his time in Europe will be hard. His time outside Europe maybe not that hard, but still. Banks will not like him. Risky scenario.

Also remember that Germany (any some other European countries) imposes exit tax. So if John leaves Germany (changes tax residence) with shares in a company he will have to pay exit tax. If he doesn't leave but has shares in an a foreign offshore company, he will have to pay CFC tax from the...

Malta for instance, but only if you are a NHR in Portugal. If you have a Maltese company and distribute dividend to a Portuguese NHR, there is not WHT tax in Malta and in Portugal you don't pay taxes either (because under the double tax treaty Malta has a right to tax but does not do it in...

It all depends on the figure of your cash out. I know that some Swiss banks accept money from crypto if only you are able to document how you got the coins in the first place (digging is not accepted). I recently talked to the guy from UBS and he told me they onboarded few cryptowealth clients...