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If Portugal NHR, what country corp for low corp tax & no CFC issues

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here2learn

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Dec 15, 2019
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#1
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So let's say someone moves or Portugal as they want to be on EU mainland anyway, and they can also take advantage of the NHR for a decade & pay no tax on foreign sourced income (say... dividends & salary from a company or 2).

What country would be wise to set-up the company, to avoid paying a large corp tax bill (as dividends are of course post profit, and so the company pays corp tax first).

Also, need to avoid CFC rules and lastly, if an in-person visit is needed for the company set-up (banks etc) ideally a mainland EU country for the corp (but if no in person is needed, even better!).

Oh, and one semi-related... NHR, am I right in thinking for Portugal there isn't a min 180 days stay required, just rent or buy a house?

Thanks in advance!
 
#2
here2learn said:
So let's say someone moves or Portugal as they want to be on EU mainland anyway, and they can also take advantage of the NHR for a decade & pay no tax on foreign sourced income (say... dividends & salary from a company or 2).

What country would be wise to set-up the company, to avoid paying a large corp tax bill (as dividends are of course post profit, and so the company pays corp tax first).

Also, need to avoid CFC rules and lastly, if an in-person visit is needed for the company set-up (banks etc) ideally a mainland EU country for the corp (but if no in person is needed, even better!).

Oh, and one semi-related... NHR, am I right in thinking for Portugal there isn't a min 180 days stay required, just rent or buy a house?

Thanks in advance!
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Cyprus would be a good option. This structure is common, 12.5% paid corp tax and then you pay nothing in Portugal.

If you are not 100% set on Portugal then Cyprus could be a good option for reocating as well, as you maintain non dom status for 17 years and therefore only pay corp tax as dividend will be sdc/tax exempt.
 
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#3
CyprusLaw said:
Cyprus would be a good option. This structure is common, 12.5% paid corp tax and then you pay nothing in Portugal.

If you are not 100% set on Portugal then Cyprus could be a good option for reocating as well, as you maintain non dom status for 17 years and therefore only pay corp tax as dividend will be sdc/tax exempt.
Click to expand...
I'm quite keen on Portugal to be honest, as have family in Spain and France, and friends in Portugal, so it seems a good option for those (lifestyle) reasons.

But I could do this, maybe?...

1) UK corp - for UK services (digital)
2) Cyprus reg company, which the UK company pays a management fee to? (or similar).
3) Me, in Portugal on NHR scheme for 10 years, drawing dividends from the Cyprus corp (and a wage from UK corp?!)

Would this work well do you think?
 
#4
CyprusLaw said:
Cyprus would be a good option. This structure is common, 12.5% paid corp tax and then you pay nothing in Portugal.

If you are not 100% set on Portugal then Cyprus could be a good option for reocating as well, as you maintain non dom status for 17 years and therefore only pay corp tax as dividend will be sdc/tax exempt.
Click to expand...
Also, what's the cost of a company set-up in Cyprus for this? Is it a service you provide, and is an in-person visit needed or can it be done remotely via email/website?
 
#7
Just had a similar conversation with a Portuguese tax specialist.

He reckons Dubai could be a good option for an interim company.

He advised against trying to receive tax free UK salary as it would be considered employment in Portugal and taxed at either standard rate or if you qualify for a NHR profession then 20% but still with social charges on top.
 
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