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Fr / Ger / Uk / Africa -> complexe Set-up

Loisir

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Feb 13, 2020
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Hi all,

I'm Bob.

Bob Is a French Citizens and national, he also handle a dual nationality with a North African country ( Morocco/tunisia/algeria). The adresse of Residence on his National Id Card from North African country is his EU address and not north African one.

Bob Is currently in Germany for an international Job so in some weeks, bob will be registered as an unlimited Tax Resident in Germany because germany work as a territorial tax. This result as Worldwide incomes have to be taxed in Germany.

Bob would Like to open a Uk Ltd because he can't in France due to his statut with administration. He can't in Germany due to his Job or doesn't have a salary from other activites.

Bob would not like to open company on Us, east EU countries as Cyprus because it will not fix any problems etc.....

Bob have made some research ( CFC, AEOI, CRS,MCAA, Etc...) and find out that considering international treaties if he open a Uk Ltd he may not fall under the Uk corporate Tax because the Ltd will be controlled from Germany so German IRS will apply ----> Then report the company to his job if he has a salary + 30% Tax etc .... Not good;
Bob Have already made the reflexion of not giving him salary so he will have no Personal income from the company , but it doesn't fix the Areas of Control from and heavy tax and the report.

Bob would like to know these :

His futur clients may be in EU for the beginning.

1/ If Bob open a uk Ltd with his north African ID , Companies House will made the Link with his other nationality ?? Will he have disadvantage with banking ?
2/ If Bob Open a Uk Ltd with his french Id, he have any solutions to avoid being reliable to Germany IRS, by law it means having substances in Uk but what ?
3/ Bob have other juridiction to look for, that will not bring problem with banking and all non-residents issues ?


The Primary target of bob is not to avoid tax. It is to optimize tax and not foremost not being reported to his primary countries of interest meaning Germany and France.

Thank you all !!!!!
 
Bob needs to sit down with a lawyer and discuss this in proper detail, unless Bob wants to find himself in a mess where he owes taxes in Germany, France, and/or UK and has his visa revoked.

Bob has already misunderstood a lot of things, so Bob is really not equipped to shoulder these responsibilities for himself.

I hope Bob finds a good lawyer and tax adviser.
 
Bob needs to sit down with a lawyer and discuss this in proper detail, unless Bob wants to find himself in a mess where he owes taxes in Germany, France, and/or UK and has his visa revoked.

Bob has already misunderstood a lot of things, so Bob is really not equipped to shoulder these responsibilities for himself.

I hope Bob finds a good lawyer and tax adviser.
hahahah very good.
 
Bob needs to sit down with a lawyer and discuss this in proper detail, unless Bob wants to find himself in a mess where he owes taxes in Germany, France, and/or UK and has his visa revoked.

Bob has already misunderstood a lot of things, so Bob is really not equipped to shoulder these responsibilities for himself.

I hope Bob finds a good lawyer and tax adviser.

ahaha Thank you for helping bob. Unfortunately Bob is aware of the new EU rule who force Third parties as accountant lawyer to give information from client who consult them for this purpose.

In addition what bob misunderstood ?

Bob doesn't have any Visa as he is French national too
 
Hi I think the most important point is the CFC rules here + the report to administration.

Does anyone know how to escape CFC, i'm also facing same issues
 
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