Help to choose jurisdiction for long-term

Hello,
I own hosting provider and for the past 8 years have been working under Dominica IBC with bank acc in Singapore.
Things are changing, Dominica is introducing 30% tax since 2021, many companies don`t want to work with offshore anymore.

Thus we are searching for the jurisdiction for the next many years to satisfy some conditions:
Payment systems (e.g. Paysera, Transferwise) are not willing to open account for offshore, even more, Paysera needs EU company to allow credit cards merchant service. So most likely we need EU company.
Jurisdiction should allow Non-EEA citizens to open company, it should be possible in the next 1-2 years to open bank account for that jurisdiction.
We do not use any nominal directors or shareholders, business is absolutely clean and legal
The only purpose is clear - to pay as less taxes as possible, accumulating rest after all expenses on bank acc (if possible).

We have considered and problems found:
Estonia: Accounting and Tax return. After 40 000 Eur you need to register for VAT and provide pricing to EU customers (which are most that we have) with VAT and monthly reports and etc.
UK/Scotland LP: Responsibility by personal assets, risks that payment systems will stop working with UK after brexit. Banks don`t want to open acc.
UK LLP: Risks that payment systems will stop working with UK after brexit. Banks don`t want to open acc. Accounting and Tax return
Ireland LP: EU residency needed. Banks don`t want to open acc, responsibility by personal assets.
Ireland LTD: 12.5% tax, not clear how much can be deducted for expenses (we have almost 90% of total income spent at the end to our suppliers of services/servers and etc), EU resident director needed (can be bypassed by EU Bond for 2000 Euro), Accounting and Tax return


Can someone advise any proper solution, so that we could register company directly on non-EEA resident, could open account preferably in EU bank, register in EU payment systems and could collect funds with minimal possible tax? No office in EU, only physical servers

Thank you
 
Last edited:

Gediminas

Offshore Tax Advisory
Mentor Group Gold
Commercial Service
Business Angel
Hi,

I usually recommend getting professional tax advice from an international tax advisor, who could make an analysis of your case and suggest your tailor-made structure. My partner tax advisor can prepare detailed analysis and advice with possible structuring options, this includes analysis of all important personal circumstances, preparation of memo with structuring alternatives, answering all related questions, conference calls, etc.

If you need a long-term strong solution, I wouldn't rely only on public information found on the internet.
 

Admin

Forum Moderator
Staff member
I agree with @Gediminas - you may also look into the UK or similar cheap countries to register and maintain a company if it doesn't have to be offshore.
 

fshore

Entrepreneur
What was the problem with Estonia?
All EU companies will have to charge vat to eu residents.
 

avalanche

Active Member
What was the problem with Estonia?
All EU companies will have to charge vat to eu residents.
by the way what if EU resident puts in their billing address another country to avoid paying VAT. will company or consumer be prosecuted?
 

Admin

Forum Moderator
Staff member
I know the law and the rules. But honestly, I have not yet seen any Cyprus, Georgia or Romenian company with troubles because they didn't charged VAT. If the companies are owned by foreigners in these countries the general tax and VAT rules has been ignored until now at least from the real world cases I'm looking at right now.

You may get troubles if you live in the UK and have a UK LTD and don't charge VAT or if you live in Cyprus and own a Cyprus Ltd and don't charge VAT but if that is not the case, I would not be nervous so far.

Anyway, things are changing and the last few years have wait up and down in the offshore world.
 
What was the problem with Estonia?
All EU companies will have to charge vat to eu residents.
What do you mean "will have to charge"?

We are making same pricing for all customers worldwide and don`t want to separate EU/Non-EU
In Estonia company has to be registered for VAT and submit monthly reports after 40 000 Euro of year turnover

For now looking at UK LLP with hope the EMIs will continue working with it.

By the way, does anybody know any EMI that will accept UK LLP with nominals from Seychells ? Paysera for example won`t verify the account if they see any offshore in the structure

And this there a change to open account in "normal" or any bank with UK LLP with nominals ?
 
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xzars

Entrepreneur
Long-term? I'd advise to get a short-term solution for the next 2 years, and then revise after the OECD commie tweaks around digital taxes and 3 pillars is concluded. The idea of a UK LLP ought to be good enough for that timeline.

Among other ideas of "OECD commie tweaks", there's an active debate of "a minimum tax" of 15%. If the offshore jurisdiction does not charge at least 15% corporate income tax, the proposal is that the market (client) jurisdiction will have the right to do so. Will the idea reach a broad consensus? I don't know. Probably not, but that's not very reassuring.

If you want a solid long-term solution today, go for a 15% CIT jurisdiction. Other solutions are on turbulent grounds. :confused:
 

fshore

Entrepreneur
What do you mean "will have to charge"?

We are making same pricing for all customers worldwide and don`t want to separate EU/Non-EU
In Estonia company has to be registered for VAT and submit monthly reports after 40 000 Euro of year turnover
Uk llp also have to register for vat, as will any other eu company, once they pass the thresholds.
 
To sum it up what i understood:

If i want to "be safe" - register LTD in EU in any country, will have open registry with all personal details (nominals are not welcomed by banks and EMIs and no sense for UK because of PSC reporting law), subject to VAT, annual returns, monthly/quarterly VAT returns and pay 12.5 - 15% + VAT

Or if i want to stay kind of with the schema that we have nowadays - need to find some solution like English LP with nominal partners + Mauritius bank acc + Hong Kong based EMI, as i don`t know if there are any EU EMIs that opening accounts for offshores or for EU companies with nominals from offshores. If anybody knows please advise. Transferwise and Paysera have declined our applications
 
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