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0% tax residency

devnull

Active Member
Dubai in the UAE is the only country, where you can get residency for just 1 day stay per 180 days.
 

jojojo

New member
what about republic of ireland, remittance basis for non doms? effectively tax free, not sure about the cfc provisions just implemented
 

GrumpyMess

Entrepreneur
I want to share my findings. Information may not be accurate.

UAE - it's quite easy to obtain a residency by forming a free-zone company, there is even no requirement to rent an apartment. One visit per 180 days is required. Price - 5k yearly and 5k one time. Drawback - tax residency certificate can be issued only if one is permanently residing for at least of 180 days.

Cyprus - there is a good non dom regime at which dividend income is exempt. You can use your offshore corp and receive profits tax free. But this is not a tested method in 2019, especially with creeping CFC rules. The benefits of Cyprus is low cost of this setup and 60-day presence rule, after which the tax residence certificate can be emitted.

Malta - remittance basis taxation. There are several residence programs, some of them have 180 day rule, the others do not. Drawback - there is a minimum taxation of 5/15/25k depending on a program and property requirement of minimum 9k. Tax certificate can't be issued if presence is less than 180 days.

Monaco - no tax at all. The only requirement is to deposit a 500k in a bank and rent a property. Drawback - there is a mandatory interview. Tax certificate can be issued after 3 months.

Switzerland - lump sum taxation depending on canton. Very interesting option for UHNWI individuals since there is a minimum tax which is quite big. Drawback - 180 day presence rule.

Italy - resident non-dom regime, just pay 100k yearly and don't care about the rest. Quite attractive for HNWI.

Georgia - has a non dom programme but it is advantageous only for HNWI, which doesn’t impose a minimum time to be a tax resident
Liechtenstein - has the same lump sum taxation regime as Switzerland, but there is no description of it.

UK / Portugal / Ireland non dom regime. They all are quite unattractive since only passive income is exempted.

Unfortunately, I still have not chosen a suitable programme
 

jackfrost

Active Member
Malta needs to be booted from the offshore business. Their sneaky ways laying tax traps and over-complicating simple matters is a disgrace. Existing legal bloat and compliance is cumbersome enough but they keep adding to it. And even when you bank elsewhere, you can't ignore the undeniable fact that the title of being the worst financial services center in the EU belongs to Malta.

If you bought (or intend to buy) the Maltese passport, they will be your friend, if not, you will need to keep an eye on that snake. It will strike when you least expect it.

To pay 0 to 5% tax, there are better options elsewhere in Europe. For long term-term stability and clarity, avoid Malta. Not residents looking to structure their passive investment funds or active trading companies can structure via Ireland, Gibraltar, IoM/Guernsey/Jersey, Cyrpus or Luxembourg. There may be other options not mentioned.

Got bitten by Sata?

Cyprus for low income, Malta for proper money is as easy and solid as it get in Europe with real business activity involved. Lots of FUD.

Also for the 5k minimum tax:

1) Easy to get around but you would not get a tax certificate and that is batshit stupid just like most of those shady jurisdictions if you have a legal business

1.1) If 5k are a deal breaker you have no business in looking into any of this anyways. You will spend a lot more on errors and unlucky unforeseen issues no matter which jurisdiction. If you are just scraping by do not do it... You might just as well go to the casino.

2) Remittance is very loosely defined. As long as you dont operate a bank account in Malta (again dont 0 reason for this) or draw money from an ATM it is actually quite hard to trigger remittance rules. Also previous savings and after 1-2 years NEW income = savings and can be remitted to malta for free.

It does not get cheaper unless you are <100k and none of those jurisdictions that the theoretisists like to advertise give you a EU VAT number in an not blacklisted jurisdiction, corporate tax certificate, income tax certificate, residency, EU banking, 1-3h flights anywhere in the EU etc pp.

If you like living on a 300 days of sun island is another issue that is highly subjective.

From a legal business in the EU perspective i have yet to read anything that comes close to being as solid, legal and easy as Cyprus and Malta.
 
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devnull

Active Member
Ok, thanks jackforst, it made my decision clear, im glad that im staying in Malta, due to my over >100k€ yearly income and big business turnover.
 

jackfrost

Active Member
Ok, thanks jackforst, it made my decision clear, im glad that im staying in Malta, due to my over >100k€ yearly income and big business turnover.
Make sure to get a proper structure setup or your current checked if your account was shit. It is easy, just use the known advisories. Dont try to save a couple thousand with proper revenue its stupid and get bitten by lousy work of your accountant / tax lawyer.

Pay the 5k. Most advisors are actually used to people trying to get to 0% but dont. 5k will be peanuts with your revenue and you will get the tax department of your back and get proper tax certificates etc pp.

If you bank on Malta then only the Maltese LTD or your private savings that are remittance tax free and only with BOV imo. Again easiest thing might be to just not bank on Malta especially private side. Two accountants i have talked with in the last weeks actually have started to just tell clients to not bank on Malta at all anymore because of all the hazzle with banking and recommend multiple bank accounts.

Stay the 183+ days as ordinary resident unless you pay for the residency schemes. Someone mentioned you do not get a tax certificate if you use those and stay only e.g. 4 days. Not sure about this i think you do get one as that is what you are essentially paying for but i could be wrong here. Can update on this soon as i might look into it myself as i am traveling a lot. If you choose ordinary self sufficient residency do the 183+ days and keep track of dates / flights / grocery etc bills.

Get the residency card + tax id.

Make sure to file and pay all taxes private / corporate / VAT etc on time! Some things like the refunds have wording that depends on this.

Don't try to game the system for another 1-2% or something like this. 1) its stupid 2) again refunds work just fine (yes there are delays with interest...) if you follow the rules.

Absolutely make sure to follow all German rules. This is as or much more important!!!
 

devnull

Active Member
Yeah, i do banking outside of Malta, im already tired of Malta banks etc. So im happy with Revolut.com and etc.

I do have my Malta LTD with my personal tax ID etc. Im already an resident offically and stayed over 183 days last year.

And yes, i try do not save everything and i pay also private income tax for my salary.
 

xzars

Entrepreneur
@jackfrost

Malta's a hellhole for all 3: legal clarity, business and banking. If diving is one of your hobbies, personal residency could be worthwhile. When it comes to diving sights, there are not many places in EU that come close to Malta and Gozo. I also like rocky hills and landscapes but the cities look absolutely disgusting due to low quality construction, lack of planning. And they just keep building more, wherever 10 sqm. of unoccupied land is to be found.

Possibly the war zones in Syria have less dust and noise than the Maltese cities.

<3
 

KJK

Entrepreneur
5k is for ordinary residence where you have to reside for at least of 180 days. 15k is for Malta residence programme and still I don't think they will issue a certificate without 180 days of presence.
I'm in a similar situation solving this as well, can you accept private messages GrumpyMess? You have the option to message you turned off.

I'd like to exchange some know-how about the list you posted above (at 00:22), not selling anything, just hoping to figure something good out.
 

jackfrost

Active Member
@jackfrost

Malta's a hellhole for all 3: legal clarity, business and banking. If diving is one of your hobbies, personal residency could be worthwhile. When it comes to diving sights, there are not many places in EU that come close to Malta and Gozo. I also like rocky hills and landscapes but the cities look absolutely disgusting due to low quality construction, lack of planning. And they just keep building more, wherever 10 sqm. of unoccupied land is to be found.

Possibly the war zones in Syria have less dust and noise than the Maltese cities.

<3
As for hellhole that is just FUD. The grass is always greener on the other side. Tell me a viable alternative in the EU with all the same pros and no cons.

Simple, live in Valletta, Tigne, Sliema but yes regular cities and construction quality planning etc is typical Mediterranean. I wouldnt set foot in the inner countryside regular cities.

You can throw away most continental cities compared to the life you can have in Valletta / Tigne / Sliema + 80% of the empty coastline with absolutely awesome lonely places if you prefer. Again nothing for people complaining about 5k tax. Also again you have to want to live on an island. Traveling is always a plus. I stay approx 190-200 days and travel the rest. The size, weather, incredible cities like Valletta and coastal areas make it the perfect living / travel base in the EU - in my opinion. Again subjective.

Malta just like Cyprus is what you make out of it and yes you need money for that. Absolutely.

why ?

5k is for ordinary residence where you have to reside for at least of 180 days. 15k is for Malta residence programme and still I don't think they will issue a certificate without 180 days of presence.
cyprus: Because then the 12.5% tax rate without having double company structure can be cheaper and living etc is also a bit cheaper depending on where you want to live and what kind of apartment etc. than Malta. Above that the 7% less tax in Malta far outweighs the higher base costs of 2 companies and living costs.

As for tax certificate as said i am not sure about the tax certificates in the 15k+ residency programs that remove the 183 days rule ( you still have a 183 day rule btw - to not reside anywhere else for 183 days).

In general the tax certificate is rather bound to 1) filing a tax return that results in a tax payment 2) having residency + tax residency. The 183 days are rather for achieving residency + tax residency but again you are getting both with the 15k+ residency programs even below 183 days and filing a tax return with a positive tax payment should get you that tax certificate with those programs too even below 183 days but yes not sure on this. Haven't made an appointment to have that verified yet.
 
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GrumpyMess

Entrepreneur
I'm in a similar situation solving this as well, can you accept private messages GrumpyMess? You have the option to message you turned off.

I'd like to exchange some know-how about the list you posted above (at 00:22), not selling anything, just hoping to figure something good out.
Accidentally turned the message option off. It seems enabled now
 

devnull

Active Member
@GrumpyMess why not just to live in UAE? the rent price there seems decent, what are stopping you from doing it in one of these countrys? I would consider UAE also, if i am lazy with tax reports and i prefer not doing it anymore.

Malta is a bit same, just keep money outside of Malta earned from other offshore business company and only pay the salary from MT company to oneself with a bit of income tax
 

GrumpyMess

Entrepreneur
@GrumpyMess why not just to live in UAE? the rent price there seems decent, what are stopping you from doing it in one of these countrys? I would consider UAE also, if i am lazy with tax reports and i prefer not doing it anymore.

Malta is a bit same, just keep money outside of Malta earned from other offshore business company and only pay the salary from MT company to oneself with a bit of income tax
It's a complex question, UAE is not that typical european country where you can come and live, there are a lot of niceties such as climate or sharia laws. I definitely do consider moving to UAE, but I don't want to sacrifice my freedom to win 5-10% in tax. Anyway UAE is in my shorlist. It remains to find out whether the tax residence certificate is required for foreign banks and my citizenship country tax office or Emirates ID is enough.

Malta is definitely not a solution for me since it has a 180 day rule. Cyprus - possible, but not Malta.
 

7889

Active Member
I would like to clarify one misconception about Malta - their residency programs don't require you to spend 180 days there. You only need to declare in your annual declaration that you haven't spend > 180 days in any other single country. Think about the difference.
 

Juoffshore

New member
Portugal is good, there is no 183 days Rules with NHR programm, show them you want to live here by renting a flat, and then travel....
Offhsore incomes are not taxed as soon as they are not coming from a country blacklisted by portugal...
 

jackfrost

Active Member
I would like to clarify one misconception about Malta - their residency programs don't require you to spend 180 days there. You only need to declare in your annual declaration that you haven't spend > 180 days in any other single country. Think about the difference.
Yes that was already clear, the issue was if you get a proper tax certificate if you choose e.g. the 15k route and only stay e.g. 1 month AND <183 days in any other country.

I know that you can definitly get a tax certificate with those programs but there seem to be special rules concerning this.

Of course people should also take into account the rules of the other countries they reside in. Many of those will force you to be tax resident just because you are staying in them longer than in any other country even if <183 days, no other ties etc pp.

So it is not as easy as just pay 15-25k a year, stay 3 days and be done with it depending on citizenship and usual residence in the other days even if you comply with Maltese laws.

Portugal is good, there is no 183 days Rules with NHR programm, show them you want to live here by renting a flat, and then travel....
Offhsore incomes are not taxed as soon as they are not coming from a country blacklisted by portugal...
Would be careful there. NHR is probably on of the most restricted programs out there.

The rules on what is considered tax free offshore income under NHR are way way way more complex than this and always involve the applicable double tax treaties etc. Usually only purely passive income, only with non blacklisted countries and only if dtt in place and the whole the other place has the right to tax but doesnt tax it etc pp. Even with passive you are looking at difference rates for different things and differing under different DTT.
 
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7889

Active Member
Yes that was already clear, the issue was if you get a proper tax certificate if you choose e.g. the 15k route and only stay e.g. 1 month AND <183 days in any other country.
You are right, but i can share some experience:
- so far, i have not seen any bank actually ask for tax residence certificate. Some banks are fine with jsut simple self-certification form (i was always wondering what would happen if one just put any non-crs country info there?). Some go further and ask for residence permit and address proof. My experience does not cover all cases, of course, but it's quite considerable. I'm more interested to see what exactly happens when Tax office of Malta receives via CRS information on, say, someone who has obtained Malta special tax status under Global residence program (i also must point out that of all numerous Malta residence programs only GRP is specifically tax-oriented one) and claimed somewhere else to be tax resident of Malta, but actually isn't.
- I know people who, having maltese residence, did the following: had someone live in their apartment occasionally (to show spending on utility bills), have someone trusted use their maltese bank card in Malta, joined gym, and tax certificated was received without any questions with actual time spent on Malta barely being two weeks in a year.
 
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