Best low tax setup for tax residency in Schengen with UAE FZ?

[mzs034]

What country is the best for tax residency within EU (Schengen) to base yourself as tax resident (renting flat, EOR, establish company), to run with an operational UAE company? What is the lowest tax setup with also ability to travel freely within EU?

I understand tax residency in UAE doesn’t matter in EU if you don’t stay 183 days, with TRC being useless, and 183 days are too much to be living in UAE.

What are the options? Malta, Portugal?

In Malta, would you need to declare CFC, I read Malta doesn’t really have defined PE rules?

Is the Portugal NHR a viable option?

 

[Milei]

Bulgaria has been in Schengen since this year and has a favorable DTT with UAE (place of incorporation as opposed to place of effective management as corporate residency tie-breaker rule). 5% flat tax on dividend income.
Cyprus will probably be in Schengen from next year on. There is a 2.65% social security tax for non-doms (capped at about 5k) but they have a standard tie-breaker rule in their DTT (place of effective management for corporate residency) with UAE, so it's more risky.

 

[SCHLOSSFINANZ]

Bulgaria is your best deal

 

[mzs034]

How would one best setup in this case in Bulgaria as EU citizen? Company or just registering to live for the tax residence? How would one structure if the plan is to move around EU?