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Best solution to transfer 150K from France (business account) ?

SasuT

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Jun 5, 2023
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Hi, currently have around 150K€ in my French business bank account.
I live in Dubai now.

I'd like to transfer the maximum of those 150K, with paying the less possible taxes.

The easiest solution -> 150K dividend -> pay the 30% flat tax -> 105k€ remaining.
It's the safest and easiest solution, but 45k are gone..

Now the others solutions I heard about.. invoice my companies between them (my French company and my Dubai company) -> Too risky I guess. The 2 companies are directly linked to ME.

But maybe something can be done with an intermediate company between those twos? For example, someone with a US LLC invoices my french company, and then my dubai company invoices his US LLC ?
Note that I'm in the gaming industry, so I can easily pretend to develop a game, and pay developers, graphists etc... for 10k-15k/month (for example).

Is it worth the try, or should I just pay the 30% tax ?

Thanks.
 
Hi.

30% tax it is a lot. If you run a company with maximum 500K Euro turnover per year, you can setup a Micro Company in Romania and you pay 1% tax/per company turnover if the company have minimum 1 employee or 16% tax on profit without employee, and 8% tax for dividends.
 
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Are you out of the french tax net / not a tax resident of France? Then I believe you can just pay the 150k to yourself as a salary with UAEs's 0% income tax. (Or does having a company in France mean one is in the tax net , Im not sure)
 
Hi.

30% tax it is a lot. If you run a company with maximum 500K Euro turnover per year, you can setup a Micro Company in Romania and you pay 1% tax/per company turnover if the company have minimum 1 employee or 16% tax on profit without employee, and 8% tax for dividends.
But it's too late, I mean, my actuel concern is how to get out the money from my French Business bank account without paying 30% taxes on the dividends.

Are you out of the french tax net / not a tax resident of France? Then I believe you can just pay the 150k to yourself as a salary with UAEs's 0% income tax.
I'm Dubai fiscal resident.
But in France, if your company pays dividend to someone then the company needs to pay the flat tax (30%) automatically, even if I'm Dubai fiscal resident (I think)

EDIT: Oh, you talk about salary, not dividend. This can be interesting.
But I think it's not a good idea, as they could just reconsider me as French tax resident, because I receive salaries from my own french company.
 
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But it's too late, I mean, my actuel concern is how to get out the money from my French Business bank account without paying 30% taxes on the dividends.


I'm Dubai fiscal resident.
But in France, if your company pays dividend to someone then the company needs to pay the flat tax (30%) automatically, even if I'm Dubai fiscal resident (I think)
How do you know it's 30%? Can you give a source?
 
EDIT: Oh, you talk about salary, not dividend. This can be interesting.
But I think it's not a good idea, as they could just reconsider me as French tax resident, because I receive salaries from my own french company.
Ok, hm, next idea, how about you "hire" a friend of yours in Dubai and pay the 150k as a salary to your friend over some months.
 
Ok, hm, next idea, how about you "hire" a friend of yours in Dubai and pay the 150k as a salary to your friend over some months.
Not possible, because I'm the only one in my company, and I can't hire anyone.

The only way, in my opinion, would be this :
Someone with a US LLC invoices my French company for prestations related to my business, for like 10-15k/month = 0% tax.
And my Dubai company invoices his US LLC = 0% tax.
Then I pay myself a salary from my Dubai company = 0% tax.

Otherwise, I don't know.

Edit ; if anybody have some ideas but wants to talk about it in PM, feel free. Not everything can be said here I guess.
 
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Not possible, because I'm the only one in my company, and I can't hire anyone.

The only way, in my opinion, would be this :
Someone with a US LLC invoices my French company for prestations related to my business, for like 10-15k/month = 0% tax.
And my Dubai company invoices his US LLC = 0% tax.
Then I pay myself a salary from my Dubai company = 0% tax.

Otherwise, I don't know.

Edit ; if anybody have some ideas but wants to talk about it in PM, feel free. Not everything can be said here I guess.
US LLC might be dangerous.
Check your pm
 
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Not possible, because I'm the only one in my company, and I can't hire anyone.
Ok, not giving up on the salary route. I mean even if you have a french single member / unipersonelle company you can still have employees. Like if you have a SASU (société par actions simplifiée unipersonnelle) as in your nick, you can have employees, no problem. And actually even a French sole trader can have employees, all types of sole trader companies: Entreprise Individuelle, EIRL, EURL. France has so many company types, but seems all of them can hire employees. Just google "est-ce qu'une entreprise individuelle peut embaucher un salarié"
 
I have nothing in France, except my company which I'll close as soon as there is no money left inside.
But my family is here so I'll surely go back time to time.
if you do so, you can't do much, as soon as you cross the boarder you run a risk with a simple check to get caught! It's too risky that way. You will need some sort of factoring service!
 
Why would a US LLC be dangerous?

I think this idea might work. There was a user on this forum offering such services, but he isn't active anymore. Who knows, maybe he's in jail.
It would be a lot of risk for someone to take on, and it would be a risk for you as well.
Honestly I think you're better off paying the 30% and sleeping well at night.
 
You could attempt interposing a company between yourself and the french company. This company should be in a jurisdiction which has a favourable tax treaty with France allowing for a reduction in withholding tax on dividedlnd or be able to access the parent subsidiary directive which allows for 0% whitholding taxes . A few other options should be available including utilizing the merger directive or migrating the company.
In all these cases you need a tax lawyer or other professional who knows what he is doing as you will be facing treaty anti shopping rules and other local french anti avoidance rules. Costs associated would be substantial for fees and running the suggested set up.
 
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Not sure if I am the only one here not seeing an issue with another company invoicing your french entity for different services. I've been doing the same although with other European jurisdictions. 150k is not even a huge amount, would be different if it's 1.5 million
 
The issue is transfer pricing and hidden distribution of profits.
For 150k and a non resident? Surely depends what is the field of business, if it's online and a bit international I don't see how that could be an issue
 
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