Right, PE would apply.
Back to the original topic, do I understand this right?
- While residing outside of switzerland fund a company outside of switzerland with debt
- Cash out the funds as dividends
- move to switzerland
- get paid from the company as loan repayment (= not considered income...
True there are no CFC, but wouldn't they still consider an offshore company taxable in Switzerland if this controlled and owned by a swiss resident?
plan to move back to Switzerland so this is indeed an interesting discussion. The wealth tax would probably be the issue for me, with properties...
For 150k and a non resident? Surely depends what is the field of business, if it's online and a bit international I don't see how that could be an issue
Not sure if I am the only one here not seeing an issue with another company invoicing your french entity for different services. I've been doing the same although with other European jurisdictions. 150k is not even a huge amount, would be different if it's 1.5 million
still battling with them for my funds, it's a lower 4 figure amount and the list of required documents they keep coming up with is just insane, I would spend more just to get all those documents produced and authenticated. UAE offshore where I am the sole shareholder/director
UK LLP with Malaysia residence (need to be able to prove 180+ days if necessary to get a TIN) with a UAE offshore company works very very well. Feel free to PM me
look at Sarawak MM2H, or S-MM2H. Rules are similar to the old MM2H, you can live in west Malaysia with the only requirement to spend 15 days/year in Sarawak state.
Oh yes he will be taxed where he is resident, regardless of where the employer is based. In Switzerland you have to distinguish what are social contributions (AHV/IV, SUVA, Pensionskasse), which are due also by foreign residents employed by a Swiss company, from actual taxes, these will not be...
The government decided to postpone taxation of foreign remittances
https://www.aseanbriefing.com/news/malaysia-issues-tax-exemption-for-foreign-sourced-income/
https://taxnews.ey.com/news/2022-0106-malaysia-announces-foreign-sourced-income-exemptions-for-resident-taxpayers-until-2026
Their support is still responsive but I keep getting the same answer that they are still not ready to proceed to refund my company funds. (lower 4 digits range)
If you are a German or EU citizen you can relocate to Switzerland anytime, not sure where you guys read you need an offer letter. Many wealthy germans just retire in Switzerland.
There is no need to be recognized as a trader, just as self employed (sole proprietorship) see Setting up your...
Yes the purpose is to conduct local business. I am told by some service provider that a limited company requires a Taiwan resident shareholder and a Branch company would not be able to issue invoices... I find both a bit weird and I could not find reference of this anywhere.
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