Recent content by mud

You might want to look for countries with Double Tax Agreements with Hong Kong. Often the DTA will deem one country or the other as the taxable authority regardless of PE or where Effective Control lies. Most of the EU uses the 6 month rule for Effective Control I've found.

Slovakia has a 7% dividend tax - one of the lowest in EU.

Yep. That's one way. 'Living off my savings' is another. 'Return of Capital' is another, especially if you've done a revaluation of the business. Paying yourself a hefty Dividend when personally tax resident in a non-dividend taxing country Paying yourself under the tax thresholds is...

Gibraltar company as a non-resident that owns a Wyoming LLC. Stopping paying yourself a salary so no income tax in many countries. (Just be careful of establishing a personal tax residency in CFC countries that extend rules to individuals)

Why - what was it like 15 years ago? I only discovered Albania 9 years ago and it's going off as far as the fastest growing country in Europe. I just spent 3 months on the beach there in an apartment under $250 a month. Nice place to over-winter in Europe. Americans have had 12 month visa's...

I wonder if you could setup a trust in a nice, tax friendly English-based country (Gibraltar, Carribean, Malta etc.) to buy the holding company and other assets. Then any German court would need the permission of the non-german country to enforce a claim. And 'piercing the corporate veil' may...

I've got something like that in France. The Visa is called the 'French Tech Visa' and so has some specific requirements as to type of business you can start to gain that visa. The visa is for 4 years, its renewable, and you can apply for citizenship after 5 years but you do have language tests...

Try Albania.

It interesting the differences in these laws between otherwise similar countries. In the English based systems, as a general rule: - The company that trades is the one that would be liable if something goes wrong - If the company had no assets then there's little for a person suing to chase -...

I guess you're worried about someone suing you and forcing you to sell your assets to pay for the court action. Like forcing you to sell the shares in your cash rich companies, or take the cash out. I'm not sure how it is in Germany but in the British system there are 'trusts' that can be...

Well, in some countries it does. Albania not. To get tax residency you have to spend 6 months of every year there. Which means, unless you're a US citz (or 1 or 2 other countries) you need a Visa to stay longer than 3 months.

Well you get Tax Residency when opening a company in Eswatini. And if you stay anywhere long enough (e.g. 6 months in Albania) then you can get tax residency. Which at 5% tax for tech businesses is a pretty good deal.

The Australian Tax Office released a new Tax Residence ruling recently. One of the harsher parts is that you need to setup a new permanent residence outside of Australia to leave the Aussie tax system. Being transient or nomadic when you leave doesn't cut it and could see you considered an...

Also, be careful of Australia's strong CFC laws that apply at the both the corporate and personal level. And then there's a defacto exit tax - CGT on deemed gains when you leave the country.

Just be careful as the DN Visa does NOT include tax residency. IMHO i twas a bad last minute change. Getting residency is somewhat harder - here's a blog I wrote last year from Albania. https://www.digitalnomadvisa.com/why-albania-will-struggle-with-its-digital-nomad-visa/