Offshore set up

[Edward010]

Hi there peeps,

Maybe someone can shed some light if I'm on the right way?

I'm a non-resident anywhere if that is possible and stick to the 183 day rule per country. My work takes me to several countries in a year so it is not that difficult to adhere to at all. I'm European citizen too and have hence a bit more freedom of movement.

Salaries received from my work are payed from Offshore companies and go into an offshore account where it stays and most payments I make are with my debit card.
Tax authorities tend not to believe that one is not tax liable anywhere and they are looking for ways to prove one wrong which brings along its on problems.

My thoughts were to set up an offshore company like in the BVI's for that to receive my salary and then maybe to set up shop and life in Cyprus or Bulgaria (maybe Malta) which I can then choose as my base and my tax residency.

What do you think? or are there any other options?

Thanks in advance

 

[JustAnotherNomad]

It is complete bulls**t that you will not be tax resident if you never stay 183 days in any country.
The rule is “If you stay 183 days, you will be tax resident”. From that it does not follow that you will not be tax resident if you stay fewer days, only that you DEFINITELY will be tax resident if you exceed that number of days. In practice the threshold is MUCH lower for any regular high-tax country. Do you think people who are out of the country for 200 days every year (thousands of salespeople would fall into that category) pay no taxes?
You can even easily be tax resident if you only spend a few days per year in a country, depending on your circumstances. Being a business traveler increases the tax risk even more because you risk corporate income taxes as well.
So you should start with getting proper information for the countries you spend time in.

 

[kkein]

To add to what @JustAnotherNomad wrote, most of the times you can find the rules for each individual country well explained online on their immigration or tax authority office. Yeah, it's never < 182 days, but always much less, and almost always with a clause that leave the tax authority the power to decide whether the country is "the center of your business".
You gotta be nomad for real, or be good at living under the radar.

 

[JustAnotherNomad]

The Big Four companies usually have very good information available online for free.

For example:
“The French definition of tax residence is very broad as it is based on personal, professional and financial criteria. A person is deemed a tax resident of France, subject to tax treaty provisions, if one of the following conditions is met by fulfilling any of the following criteria.

• The individual has their home or place of habitual abode in France - The home is defined as where the taxpayer and their family normally live.
• The individual carries on a business or a profession in France, unless they are able to demonstrate that this activity is only ancillary;
• The individual’s center of economic interests is in France (e.g. the individual’s assets are located mainly in France).”

Source:
https://home.kpmg/xx/en/home/insights/2014/04/france-thinking-beyond-borders.html
As you can see, there are lots of ways for French authorities to claim you as a tax resident. There is not even a mention of any specific number of days.
So if you spend more than a handful of days in France, you better have proper residency with local ties in a country France has a tax treaty with. With a house, family, a gym membership, newspaper subscriptions, friends, ... not just something on paper.

 

[Edward010]

That is correct, I meant a maximum of 183 days and then all the other little tricks which make you a resident if you have family and other ties to the country. Switzerland even already claims taxes if you have been living there for only for 90 days.
A few countries do give tax breaks if you are outside the country for work or else by the way.
I travel a lot with my work and don't agree to pay high tax rates to a country where I might only spend 4-6 months in and hardly use the infrastructure or its services.
Digital Nomads seem to be more recognised now in a few countries then before, not that I'm one but am on the road just as much at times.
Cyprus seems to be a more and more on my radar.