Question Refusal of 70-90% Income Exclusive in Italy, What Netx?

[A1988]

Just wanted to bring to everyones notice that my request has been refused for 70-90% exemption in Italy stating "I did not move to italy with the intention to take the 70-90% exemption of income". I was involved in Research and Development activity and finished the R&D in 2023 and moved to italy in 2019. Again, I did not make any income in this period in Italy and now when the time came for commercialization of the product I am stuck with this huge blow. I have my R & D in Italy and a business partner based in Italy, hence I moved.
My present situation is that,

1. I would like to move out of italy without creating any problems or trigerring any issue with the tax authorities.
2.I would like to move to either UK, Ireland, Malta (less preferred0 and take advantage of non dom program also I have 2 kids who would start their preschooling.
3. I would like to know if anyone knows if a structure where I pay 0-5% in corporate tax?
4. I have my business partner and R and D in Italy so daily flights would be a plus, ideally within 2hrs and not more.
5. I am expecting capital gains in the next 3-4 years.

Any suggestion or experience of the situation would be very welcome, I would want to stay in the country permanently and want my children to build their life and network in it, I am not really interested in Middle eastern countries as I have lived there and I feel its not best for my children to be exposed to that lifestyle and specially having daughters. I turn 35 in may this year.

sorry for excessive information, just wanted everyone to know that the regime can come up with any kind of excuses to refuse of accept what suits them or their objectives.

 

[A1988]

What's the problem of living in Portugal for the amount of time required to cash out?

Are you sure I will not be taxed if my investments or holdings outside portugal is not passive? For sure I can hire a director but my capital gain or any income outside portugal will not be taxed?

Are you Dennis Rodman or what?

I am RISHI SUNAK, I know the UK will go to the shits sooner or later

 

[Marzio]

For sure I can hire a director but my capital gain or any income outside portugal will not be taxed?

My understanding is that if you don't actively manage the company from PT, foreign income will be exempt under NHR.

 

[A1988]

My understanding is that if you don't actively manage the company from PT, foreign income will be exempt under NHR.

I am Considering living in portugal under NHR but near the spanish border, is there any limitation in NHR regime? What if my capital gain is more than 2m Euros? Someone told me NHR is good for someone who has net income or wealth of less than 2m euros? Is that correct or I am missing something?

 

[A1988]

What about exit tax when you relocate from Spain to Portugal?

you have any idea about nhr structure that works? like cyprus holding company or gibralter?

 

[JustAnotherNomad]

you have any idea about nhr structure that works? like cyprus holding company or gibralter?

I believe that Portuguese lawyers typically set up companies in Cyprus or Malta to combine with NHR residency, but I don't know any details about that.
It would kind of make sense since those countries have the lowest taxes in Europe. But in theory, I guess it should work with other countries as well.