Sure, feel free to get in touch. Can provide turnkey solutions (EE, CY, MT, and others)
A great solution is to have a holding company in Estonia with a branch office in Cyprus:
- Profits from the Cyprus branch (PE) can be redistributed tax-free on the Estonian level (think about securities trading with 0% tax, IP Box 2.5%).
- Estonian company itself can keep Estonian trading income at 0% tax (assuming you don't distribute profits directly and reinvest)
- There is no WHT tax on dividends; you either pay 20% on a local level or redistribute foreign permanent establishment profits tax-free.
- There is no WHT on interest on loans from Estonian companies to non-tax residents. The entity owner can give himself a loan with certain structures.
- In Estonia, taking assets out of a permanent establishment is not deemed to be taking out assets or posting them as collateral in connection with financing securities if the assets are brought back, or the collateral is released within a period of 12 months.
- Tax residency doesn't require physical presence, and you're not on an island. You get a tax residence certificate based on whatever DTT automatically issued to you any day you want. Coliving space rental can cost as little as ~100 EUR/month with mail handling, or you can acquire a cheap property for less than 10k.
- For regular trading income, another great structure is to have a fiscal unit in Malta with the EE holding; this way the effective tax is 5%.
+ more structuring possibilities exist for a 0% tax income, income deferral (recommended when you have higher risk), avoiding disclosures, etc.