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Money Transfer from an Offshore to an Onshore company

ZurielS

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Nov 21, 2018
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I'm a freelancer from Austria and living between Austria and Bulgaria.
I have an LTD (EOOD) and even the tax residency of Bulgaria (but it's, unfortunately, useless as my family is still in AT). So I can only prove my company was and is managed in BG and use the 10% corporate tax instead of AT 25%.

Now I would like to invest in AT (Real Estate). I've heard the best way is to do it through an AT GmbH (LTD).

Here the question:
What's the best way to move the BG-LTD money to the AT-Company, without receiving it as dividends? (I don't want to take the risk and pay the AT income taxes / Family = AT-tights ).

I don't want to create legal links between those 2 companies.

I heard of giving a loan with low interests from one company to another. How safe is that? As I'm the owner of both.
Is there any other method or ways?

I'm even open to create other structures in other places.
 
I heard of giving a loan with low interests from one company to another. How safe is that?
Well this can work but need to be backed up by and tax attorney in order to be legal trusted. Otherwise you want to check with a tax advisor locally what options you may have to transfer money between the two entities.
 
I think the problem is, whatever action you take it will be artificially created. So if you transfer funds either directly from one company to another or create a middle man in another location, the situation will not be a genuine trading one and so will be disregarded by the tax authorities.
 
I think the problem is, whatever action you take it will be artificially created. So if you transfer funds either directly from one company to another or create a middle man in another location, the situation will not be a genuine trading one and so will be disregarded by the tax authorities.

So how should I make the transfer?
And where do you think there might be a problem, in AT or in BG?
 

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