Recent content by vs90

Hello! I saw you know people who have used/use the Malta non-dom residency + US LLC setup. Do you happen to know more about how they keep compliance? Thanks a lot!

Hello! I saw you use the Malta non-dom residency + US LLC setup. I am moving to Malta this year, and was thinking about Malta Trading + Cyprus Holding. However, I know some changes are coming up in Cyprus, plus the EU's Unshell directive. I am therefore looking at the US LLC setup again, but...

This works only if management and control are NOT in Malta. If they are, Maltese Tax Authorities will treat that income as Maltese earned, and not as a foreign dividend. It looks to me that it's quite unlikely they will find out if it's never remitted, and you can sustain your cost of living...

Ideally 0 :D But I am willing to pay a bit if this is going to make the structure safer. I am hoping that as a pass-through dividend (parent-subsidiary EU directive), this will not be taxed in Italy and flow directly from the Malta trading to me in a foreign account. The worst case I think is...

Thanks for the advice. I am thinking about whether it makes sense to have the holding in Italy, where my brother could be MD and ensure substance. I can put other investments in companies under it, so perhaps it would make a stronger case. However, I'll have to see if the dividend from Malta...

I think we're talking about different things? I am referring to the 5% corporate tax, which the company has to pay if there is a fiscal unit. Separately, I'll have to pay the 5k fixed income tax as a natural person. This I plan to maximise by earning a salary that results in the 5k income tax...

Thank you all for your help here. I decided to move to Malta. Now it's about figuring out the best tax structure: I don't want to do the US LCC thing because I want to sleep well at night :D I am most likely going to go for the Malta Trading + Foreign Holding The Malta Trading part is easy...

I have been speaking with a few providers for the following setup: Malta Trading Co + Foreign Holding Co set up as a fiscal unit to achieve the 5% corporate tax The idea is that I won't remit into Malta the foreign dividend because I can cover the cost of living with remitted foreign capital...

Because you'll have to pay for living expenses. If they are foreign capital gains, they'll be tax free. But as far as I know you still have to pay the 5k minimum tax. Makes sense!

I got it, it makes sense. Such a setup could be sensible if someone lives with foreign capital gains, which are then remitted tax-free (except the annual 5k.) To make this compliant the LLC would have to be managed by someone else and not in Malta, although Malta would probably not care too...

Has someone ever looked into a US LLC as a passthrough entity + Malta non-dom resident? Let's assume that 1) the US LLC is effectively managed by someone else in another non-US and non-Maltese country, so it does not trigger US or Malta tax residency, and 2) the person can sustain their annual...

I assume the substance requirements are minimal compared to a trading company? What if once per year I travel to Estonia to decide on the dividend distribution + other admin work? Realistically there wouldn’t be a lot more work (management and control) performed from Malta for the holding. For...

I will unlikely sell the company, but moving it under a Cyprus company in that event makes sense. I thought a similar outcome could be achieved with an Estonian holding + Maltese trading (fiscal unit), with the Estonian holding passing through the dividends to me without any withholding or...

Thank you, Don! I think I read that you don't necessarily need to pay a director's fee as the owner. Wouldn't this be the smartest setup? Only one Estonian company that pays out all of the profits via salary, which is then NOT remitted to Malta? It's essentially a 0% tax setup except for the...

Hi everyone! I am new to OffshoreCorpTalk. I found the threads so interesting I was up until 2 am reading last night :cool: I am trying to identify the optimal tax setup for my fully digital professional services firm. Let me give you a bit of background. I provide corporate finance services to...