Maltese TradeCo and HoldCo - Non-Dom EU Resident

[aniglo22]

What I would do personally is following :
Malta company → Branch in Bulgaria (operating ),
or
Malta holding → owns a significant stake in your Bulgarian LTD.
In both cases, you would qualify for a 100% tax exemption on income arising from the branch or the LTD.
Then you can use the holding to invest .

Use the Malta’s participation exemption ( also applies on Branch profits ):

The participation exemption may also be applied to any gains or income derived by a company registered in Malta that attributable to a permanent establishment, including a branch situated outside of Malta or to the transfer of such permanent establishment, whether such permanent establishment belongs exclusively or in part to the company registered in Malta.

You can’t avoid taxation in Bulgaria because the real economic activity is carried out there.

 

[DomOCT]

Yes. BG entity invoices the US and we file an annual declaration to the IRS disclosing the connection between the 2 companies and clearly stating we have no US base of operations.

This is not what pass through entity means

 

[bulgarian]

Hello bulgarian, could you give some details on government harassment? i am considering establishing a base in Bulgaria for residence and business and wonder what to expect from the government.

You get your accounts/assets frozen for no reason (without any guilt or court order). It's called preliminary collateral measures, lol. You're frozen an unable to operate while they "conduct due diligence". It's also slow as s**t. It's how they bribe you after that. Even if you've done nothing wrong, once you start making a certain amount of money (say over a mil a year), you become a target instantly.

 

[AndyAresa]

You get your accounts/assets frozen for no reason (without any guilt or court order). It's called preliminary collateral measures, lol. You're frozen an unable to operate while they "conduct due diligence". It's also slow as s**t. It's how they bribe you after that. Even if you've done nothing wrong, once you start making a certain amount of money (say over a mil a year), you become a target instantly.

thanks for these details. it does sound bad. but if someone starts out as a small fish , single member limited company, and stays in the range of 300-600k EUR per year, do you think he can still be a target for the authorities (or mafia)?

 

[bulgarian]

thanks for these details. it does sound bad. but if someone starts out as a small fish , single member limited company, and stays in the range of 300-600k EUR per year, do you think he can still be a target for the authorities (or mafia)?

Safe for lower amounts but as soon as you get in the millions the problems begin. From cops bribing you on the road if you drive a nice car, to regular invasive audits of your company and you as an individual. Better get a good accountant and lawyer (not cheap). The bureaucratic burden is immense, almost nothing electronic and absolutely nothing in English