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Estonia, Lithuania and Latvia for a holding company

That would kill any holding company. Countries like Ireland, Luxembourg and Cyprus could just close most of their companies. There are lots of legitimate holding companies with lots of substance. I can't imagine it will be implemented like that... Is this really past the draft stage?
As an alternative, what if you were directly owning the shares in the companies and then receiving dividends as a tax resident of Estonia, Portugal (NHR), Cyprus or Malta? I think there shouldn't be any tax in such a case either?
 
That would kill any holding company. Countries like Ireland, Luxembourg and Cyprus could just close most of their companies. There are lots of legitimate holding companies with lots of substance. I can't imagine it will be implemented like that... Is this really past the draft stage?
As an alternative, what if you were directly owning the shares in the companies and then receiving dividends as a tax resident of Estonia, Portugal (NHR), Cyprus or Malta? I think there shouldn't be any tax in such a case either?
That is up to each tax treaty, how much of the dividend that would be taxed when paid out to a person (not company). In the case of Sweden->Estonia, Sweden would withhold 15% tax. Same for Cyprus, Malta and Ireland. For Portugal it seems to be 10%. I only went through the Swedish tax treaty with the mentioned countries.
And this is only withholding tax where the company is tax resident, then you could (would) be taxed where you are a tax resident as well.
 
Ah, good point. I mentioned those examples because they all shouldn't have any tax on received dividends.
I would suggest that you speak to a Swedish tax lawyer and ask what he/she thinks about an Estonian holding company and this new "Unshell" bulls**t...
 
Sorry for becoming silent, I just haven't proceeded.

The actions are like a two-part rocket, simplified:
1) register and move ownership
2) pay out dividends

So, first to register an entity in EU is pretty straightforward, if you don't know the language/process there are a lot of companies that can help. Then you need some tax advise on moving the ownership and with that any tax owned needs to be resolved and voila, you have your corporate group.

The second part, to actually pay out the dividends can or cannot create implications, when the transaction is between corporations within EU. Are we talking tax planning (my take on it) or tax evasion (greedy politicians take on it). What do you need to prove that the holding company is acceptable to received these dividends (I believe @Martin Everson already touched upon this). Local directors, local employees, a local office, local business engagements, etc, etc.

On top of this you would need to register a bank account, either through an EMI or a "regular" bank and things can get complicated if you are not an EU-resident - EU-citizenship is not enough as of my experience.

And the final step, to actually payout the dividends to you is filled with questions and uncertainties - which made me not move ahead quite yet. You may, or may not, be taxed for this, depending on a lot of circumstances that might not be known once you setup the holding company/structure and make the transaction.

Currently I am looking at incorporating a holding structure with a holding company in either Netherlands, Estonia or Ireland. And no, it is not going to be tax free and there is a cost of doing this. So you need to know exactly what your break-even amount is so the costs don't exceed the actual net amount received on your bank account, either if it's a one-time occasion or a x years plan.

But reading tax treaties, asking "dumb" questions to lawyers and simulating the dividend flow keeps you pretty occupied to find a good solution :). I am determined not to give away part of my(!) money to greedy politicians that already receive/d so much so the quest continues.

Somebody asked for contact info to the lawyer I have talked to: I would hold my horses till I can really make a recommendation. I talked to some tax lawyers over the years, engaged with some, and as most of you already know, the cost/value is not always that favorable...as you would expect (more favorable to them, I would say).

So, to conclude, there are a lot things that you need to be certain of and you can only trust yourself, so it takes time to understand and of course things (laws) change as well, as I pointed out regarding the new EU-directives in the thread.
 
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