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EU company + Mauritius Foundation?

mange38

Entrepreneur
I have a company in the EU which is currently in my name and I am in the UBO register as well. Most of the double tax agreements my country has signed propose a 5 to 15% withholding tax on dividends. However, there is a DTAA with Mauritius and it says there is 0% withholding tax. Would it be possible to form a Mauritius Foundation so it owns my local company? CFC rules are not an issue in my country.

I also found the following post: What is required to form anonymous Swiss GmBH or AG ?

"Set up a structure like this: 1. Normal Company (with nominated directors) 2. The company is owned by a Foundation (Mauritius) which is considered a "person" with rights and privileges just like a natural person. It has a board of directors, no UBO, only beneficiaries and a Founder who are legally separated from the Foundation assets. In this structure, you will not appear on any public records, nor private records..."

Is this setup possible in the EU?
 
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mange38

Entrepreneur
CFC rules or an effective management rule are enforced in all of the EU
In my country, CFC only applies to subsidiaries in low tax jurisdictions. I don't want to sound rude but please stick to the topic :rolleyes:

Also the whole point of this is to move out of the EU, preferably to Georgia or somewhere else so CFC definitely won't be a problem in regards to the Mauritius foundation.
 

mange38

Entrepreneur
Move to Georgia and don't waste your time with what your looking into.
I will but I want to keep my company in the EU since I already have employees here and I would pay more corporate tax in Georgia (I currently pay less than 15%).

I will also inherit one more company here so it's not that simple. If I 'just' move to Georgia I will have to pay withholding tax in my home country, which is what I want to avoid (& also protect my assets).
 

Martin Everson

Offshore Retiree
Mentor Group Gold
Elite Member
I will but I want to keep my company in the EU since I already have employees here and I would pay more corporate tax in Georgia (I currently pay less than 15%).
Georgia has a free trade agreement with EU and Georgia companies have a zero tax rate on profits not distributed. If operations can't be moved then thats another issue and I get that.

I will also inherit one more company here so it's not that simple. If I 'just' move to Georgia I will have to pay withholding tax in my home country, which is what I want to avoid (& also protect my assets).
I guess you don't want to say your home country so I can't really help as I don't have a crystal ball or want to guess on what you are telling me about your home country conf/(%.
 

mange38

Entrepreneur
I guess you don't want to say your home country so I can't really help as I don't have a crystal ball or want to guess on what you are telling me about your home country conf/(%.
I am from Croatia. 12% corporate tax up to 7 million HRK yearly revenue as of 2020 (so basically 1 million euro).
 

Martin Everson

Offshore Retiree
Mentor Group Gold
Elite Member
I am from Croatia. 12% corporate tax up to 7 million HRK yearly revenue as of 2020 (so basically 1 million euro).
I see thats a a lot of revenue.

Withholding tax with Georgia for dividends paid to Georgia is only 5% under the DTA.
 

mange38

Entrepreneur
On 100k EUR profit I would pay 12k of corporate tax (12%). Then on 88k I'd pay 5% withholding tax, which is 4400.

I would rather have a foundation (for asset protection as well, since it would also own apartments) than pay €4.5k to the government ns2

Not sure how much a Mauritius foundation would cost and how hard would it be to get a bank account for it though.
 

Martin Everson

Offshore Retiree
Mentor Group Gold
Elite Member
I would rather have a foundation (for asset protection as well, since it would also own apartments) than pay €4.5k to the government ns2

Not sure how much a Mauritius foundation would cost and how hard would it be to get a bank account for it though.
A foundation will cost you much more than this to maintain I can tell you this firsthand.
 

mange38

Entrepreneur
Thanks for the info, I wasn't aware of this. How much do they cost anyway? €10k/year? more?
 
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