Best Jurisdiction For Offshore Real Estate Holding?

[FreedomSearcher]

So I'm planning to start investing a lot in real estate. (6 figures a month, EUR)

I'm currently a Dubai resident.

What would be an ideal jurisdiction for a real estate holding company?
Could an offshore real estate holding company lower any taxes?
Could it protect the assets?
Could it add anonymity?

Mainly looking at EU real estate. (Belgium, Netherlands, Spain, France, Germany)

Interested in any information related to real estate holding jurisdictions and advantages/disadvantages.
Thanks.

 

[JohnnyDoe]

A US LLC will work fine.
You can’t avoid taxes but you achieve all the other objectives without the drawbacks of the usual small islands companies.

 

[saponaire]

Doesnt the US solution give you Estate tax issues at your death?

 

[clemens]

You will get taxed where you live, rest assured.

 

[saponaire]

Lol, that's way different than us estate tax!

 

[Golden Fleece]

Doesnt the US solution give you Estate tax issues at your death?

Yes, but there are ways around it. The issue was discussed in another thread.

 

[FreedomSearcher]

Yes, but there are ways around it. The issue was discussed in another thread.

Can you please refer me to that thread?

 

[Golden Fleece]

Can you please refer me to that thread?

I do not have the time. You can just Google "how do foreigners avoid estate tax" to obtain some articles, such as these ones:

https://www.jmco.com/nonresident-alien-tax-trap/
https://en.megastelum.com/library/f...ard to the ideal,with respect to the property

 

[neweraoffshore]

You will get taxed where you live, rest assured.

with real estate it gets even more complicated. Not all countries allow real estate to be hold via foreign entities. And some countries like for example Germany may even land you a tax liability on world income in unlucky cases. And the next problem is that most base erosion schemes wont work as the real estate market is a very transparent market for the taxmen. Last but not least, all countries @FreedomSearcher mentioned will tax the rents as locally sourced income, no matter where he lives.

Best chance is to look into every country specifically and, depending on the amounts of real estates and sizes, form a company offshore which then hires local asset management companies to take care of everything and you agree on a commission with them which you can take offshore tax-free, because you wont be able to receive the rents tax free anyway as they count as locally sourced income, so the best adjusting screw is the erosion via "expensive" asset management. Doing the asset management by yourself spanning multiple countries with very different regulations is mission impossible if you want to do it as an investment and not a full time job.
So, yeah, its complicated. Very...

 

[clemens]

all countries @FreedomSearcher mentioned will tax the rents as locally sourced income, no matter where he lives.

That may be the point of all of it, you can't escape taxes.

 

[Golden Fleece]

So I'm planning to start investing a lot in real estate. (6 figures a month, EUR)

I'm currently a Dubai resident.

What would be an ideal jurisdiction for a real estate holding company?
Could an offshore real estate holding company lower any taxes?
Could it protect the assets?
Could it add anonymity?

Mainly looking at EU real estate. (Belgium, Netherlands, Spain, France, Germany)

Interested in any information related to real estate holding jurisdictions and advantages/disadvantages.
Thanks.

This article highlights some of the various competing issues that you must consider:
https://www.overseaspropertyalert.com/find-out-the-best-way-to-hold-real-estate-overseas/

 

[MiddleEuroAsia]

as @neweraoffshore Said, it depends on the country that you want to invest in, but I want to ask, why not forming a holding Company in dubai since you are a resident there?

Other options, I would choose Labuan, and you can have great banking with DBS singapore if you setup your labuan structure right. (although the Current malaysian Government is acting up (look at how they handled the MM2H program) so it can be a little tough if you want future stability).

But the Clear winner is Of course - singapore. Since most of your investment will be in the EU and outside of singapore and most of the directors (beside the nominee director) are living outside singapore and key desicions are made outside of singapore (easy, since you live in dubai), your can have a non-resident investment holding company with access to great banking. This is from a Real world experience and the SG IRAS also confirm this, See: Tax Residency of a Company

I Suggested labuan, because it is great if you want to live in malaysia, since it gives you a 2 year director visa for you and your family and you can live in malaysia (cheap when compared to SG) , have a 0% tax holding Company in labuan that holds 0% non resident investment SG company with Great banking in singapore, recieve dividends tax free as a director of the labuan company (there is also no dividends tax from the Singapore side), and all in all 0% tax free in asia.

If you are happy and content in Dubai, then swap labuan holding with a dubai holding and you will have access to the same benefits minus living in Asia, and 0% tax all around.