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Recent content by walako

  1. walako

    Personal tax numbers

    @daniels27 Thank you for responding, yeah, I understand and do report :rolleyes: and I know that legal enteties have its own tax registration, it is another thing. Although, I assume if I have a Portuguese NIF number and have a Portuguese company registered with it, I am not supposed to report...
  2. walako

    Personal tax numbers

    I have a confusion with multiple tax numbers. Maybe someone can clarify how usually people tackle such situations. I got the following three tax numbers: 1. Tax number (TIN) from my country of origin, 2. also received Portuguese NIF, 3. and Spanish NIE. Now I have an entity registered...
  3. walako

    MiCA regulation for EU licensed Crypto Companies.

    Hi all! I am more or less familiar with MiCA, ahtough I do not now how to apply it to my client's situation It seems there is a company in Estonia with associated crypto assets, even though these assets are not officially accounted for on the company's balance sheet. Those tokens exist...
  4. walako

    Big number of shareholders in the LTD company (UK)

    Hi @Sols Thank you very much! I am familiar with one of the services, we did intro, but at that time I did not think about shareholders number. I know that DIY is feasible, but I am super busy with other stuff since I am a solo inhouse lawyer at this moment. Hence I am happy to receive your...
  5. walako

    Big number of shareholders in the LTD company (UK)

    Hi all! I am more or less experienced lawyer, although I am confused how to tackle the matter when a company has many shareholders. It is an obvious problem (time and money) to make corporate structure changes to LTD company in Estonia, because we need to involve the notary, translators etc. It...
  6. walako

    Avoid Permanent Establishment in EU

    Hi al! If somebody can clarify this or tell whether it is possible to find on the internet. What are the other implications of the PE. If the company, which was incorporated in the UK, then deemed to have a PE in the EU country, how the sale of shares should look like? I understand that the...
  7. walako

    Would Portuguese CFC rules apply to UK entity, UAE entity

    Thank you @JustAnotherNomad for elaborating that! My brain was oversimplifying and perception "PE" and "PoEM" as all the same sh*t, which is apparently different, and now I finally realised the difference. Main purpose of UK Co is to play a Holding role and accept investments, give loans. No...
  8. walako

    Would Portuguese CFC rules apply to UK entity, UAE entity

    dear JustAnotherNomad Thank you for the response! I am aware about PoEM issue that is super crucial. Most likely that is impossible to avoid, given that the key shareholder/director lives in PT, company rents office there for contractors and top managers. In the worst case scenario with the...
  9. walako

    Would Portuguese CFC rules apply to UK entity, UAE entity

    Hi all! I am confused by some basic CFC rules in Portugal and its interpretation. 1) Would Portuguese CFC rules apply to a UK Holding Co, if that owned by a Portuguese tax resident? Or if the UK tax authorities impose 25% CIT rate - that eliminates that the non-resident entity is a subject...
  10. walako

    Valuation vs nominal value - tax outcome

    Dear @ElBotellon Ty! Very helpful anyways! Also, me knowing that person, family circumstances, business can't calculate even assumable digits. Too complex matters: double residency (UA and PT in fact) + personal taxation, multiple CFC, reorganisation, possible exits, ATAD GAAR, place of...
  11. walako

    Valuation vs nominal value - tax outcome

    @ElBotellon Thank you very much! <3 I am aware of shares exchange, easy doable in the UK, also seem to be ok in the EU countries. Portugues lawyers offered me EUR 5k service cost to make that transaction :D I am happy to pay them for other services, but in this case I do believe that is a...
  12. walako

    Valuation vs nominal value - tax outcome

    Hi all! I am a young lawyer, and I am questioned how are business assets valued vs tax implications in the EU. 1/ For example there is a Trading Company which makes revenue 5m per year, although the share value is 5k euro at best. I am trying to get an understanding on how these assets can be...