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Philippines as the ideal place for place of management of an offshore company?

Let me see if I have this straight:
  • if you incorporate in a country where corporate tax liability is based on where it is managed (or where there is permanent establishment)
  • And don't declare a place of permanent establishment
  • And have it managed by a nominee director in the philippines (or BVI or Hong Kong at presumably higher expense)
  • And (I'm assuming) do the company banking in the country of incorporation
Then you can leave the proceeds/profits in the corporation, tax free... Correct?

What are the best countries for incorporation with this strategy? You mention Bulgaria, Slovenia and Cyprus... Any others come to mind?
IF

You are a tax resident in a country without CFC rules which would make your offshore company tax liable there by the mere fact that you as a natural person are tax resident there

AND

Incorporate in a country with zero corporate tax for companies incorporated there - most known tax heavens, for example, BVI

AND

You have a director in a country where this would not make the company tax liable in this country because you have a director there (could be BVI as well)

AND

You do the business activity from another country without declaring permanent establishment and you are aware of the consequences,

then you will pay no corporate tax but you will still need to pay personal tax on the dividends you withdraw from the company.

For the permanent establishment please keep in mind that:

1) this could be a vague interpretation, for example if I am not wrong OECD states that permanent establishment needs to last at least 6 months.

2) The other thing is that some countries may have very aggressive tax office which may hunt the permanent establishment and try to prove that it is there, for example Spain is well known for their aggressive tax office and I would not do this there. For bigger amounts of undeclared tax you can go also to jail in Spain.

None of Bulgaria, Cyprus or Slovenia would give you tax-free incorporation. I said from lawyers in this countries I have stayed with the impression that it could be fine not to declare permanent establishment there.

If you need to work on such setup you need to start looking into tax heaven jurisdictions. Different jurisdictions serve different needs but for crypto trading for example and probably in most cases almost for everything in my humble experience BVI is the best both for incorporation and for a local director there if you can afford it.

To my knowledge bank account itself would not make a company tax liable in the country of the bank. However if in this same country you are doing something obscure like hiding permanent establishments or being tax resident there it is not a good idea to have the bank there.

That being said it is extremely difficult and nearly impossible to open bank account for offshore jurisdiction and if it is for crypto trading your options are limited to probably a few banks in the world which would require very big deposits. It's virtually impossible.

PWC has plenty of useful info. You just switch on the respective country and you can see the CFC rules, PE rules, personal and corporate residency rules, the tax liability etc...
 
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The Philippines can be an offshore jurisdiction too. There is an option to have a Filipino Company with 0% tax. There is a port, mainly used by online casino's etc where you do not have to pay taxes as long as your company is resident within the area. There are maybe some restrictions that you do not have business in the Philippines, but I am not sure right now. The only problem I can see is, that a foreigner cannot directly own a company there.

The infrastructure is not that bad anymore. I do not live within a big city and I can count the brownouts with 1 hand over the last 8 years. For a second can happen sometimes but that you can manage with a UPS. I even bought very remote some land and I got directly my electricity connection even without a house or anything build there. Internet is also already okay for an Island. 8 years ago it was pretty bad.

As a Freelancer Philippines would be a bad choice, because even (Transfer)Wise do not offer anything to Philippines residents anymore right now. The Filipino Banks also do not like to get money from outside the country or you have always trouble. Like me I normally receive money monthly from Europe, but need now also to see where I can get an IBAN in my name.
 
As a Freelancer Philippines would be a bad choice, because even (Transfer)Wise do not offer anything to Philippines residents anymore right now.
For permanent residents of the Philipines, Wise has the same on offer what they always had on offer. Just that the fee structure has changed (more expensive) and the maximum monthly transaction amount is now in-line with BSP regulation. Reason: Wise PH is now a local EMI. -> Wise Account in the Philippines | Wise Help Centre
The Filipino Banks also do not like to get money from outside the country or you have always trouble.
There is no trouble. Just use a reputable bank, have a reason for receiving the amount in question, and present the necessary if the amount exceeds the BSP limit.
 
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