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Recent content by marble123

  1. M

    60 Day Cyprus Tax Resident Valid For Tax Treaty Benefits?

    Granted that: 1- Ideal is to work for dispute to be prevented 2- If one is considered tax resident in Spain, CY will not fight the case However, and correct me if I'm wrong, an individual can dispute the authorities claim over whether he/she should be considered a tax resident. Should Spain...
  2. M

    60 Day Cyprus Tax Resident Valid For Tax Treaty Benefits?

    Thanks again - 100% agree that should seek legal advice from a professional. Back on the topic of 'centre of economic interest', a term which, perhaps intentionally, is not well defined. As I understand this refers to the geographic source of income/investments/assets. Let's take a...
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    60 Day Cyprus Tax Resident Valid For Tax Treaty Benefits?

    Thanks @Marzio Would selling the shares to the CY LTD indeed cut ties with Spain (or would it still be an issue since I am the UBO)? If not an issue and it does indeed mean that I cut ties with Spain, I could in theory continue to be a Cyprus 60-day Non-Dom and not face any risk from Spain...
  4. M

    Part 2: Would this set-up trigger tax residency (in Southern European country)?

    Reading this thread seems OP and I are in similar situations. Would the Portugal NHR (and spending +183 days in Portugal) not be a good option?
  5. M

    60 Day Cyprus Tax Resident Valid For Tax Treaty Benefits?

    Thanks for getting back. Spanish citizen and 50% shareholder Selling the shares to the Cyprus company is preferred over the NHR option, but are there any potential drawbacks/downsides for the cyprus company owning the shares in the long run?
  6. M

    60 Day Cyprus Tax Resident Valid For Tax Treaty Benefits?

    Similar situation to @JohnJ81: *Cyprus Non-Dom *Cyprus company *Dividends from shares in a Spain company as main income (I do pay the 5% withholding tax) *Less than 183 days in Spain // No home // no wife or kids Article 4.2 of the DTT Spain/Cyprus states regarding residency that: “he shall...
  7. M

    Dividend Distribution - best process?

    0.75% crazy indeed.. will try Wise and update on how it goes I believe so.. this is with Hellenic
  8. M

    Dividend Distribution - best process?

    bummer.. with all the docs in order (financial statements, dividend resolution, tax declaration, etc) let's hope for the best!
  9. M

    Dividend Distribution - best process?

    it's probably overthinking indeed, but yes: want to avoid using ES IBAN just in case I want to avoid CY bank because of the outrageous due diligence charges - what's the worst that can happen if I transfer a dividend to a (very) recently created Wise account?
  10. M

    Dividend Distribution - best process?

    strangely I managed to open one (with details of my CY address). i hope i don't have any issues after having made the transfer..
  11. M

    Dividend Distribution - best process?

    lolll seems like this dividend will be paid to the new Wise account..
  12. M

    Dividend Distribution - best process?

    the swift charge is only 5€ - it is the due diligence fee which is the killer!
  13. M

    Dividend Distribution - best process?

    turns out the Cypriot bank is charging a commission of 0,75% over the received dividend amount - seems too high?
  14. M

    Dividend Distribution - best process?

    thanks! will follow this advise
  15. M

    Dividend Distribution - best process?

    yep - i think thats only available for the premium plans