You don't need to move to use a Holding company setup or putting another company between the supplier and Swedish company with a lower corporation tax rate. As long as the funds remain in the corporate structure you do not need to pay capital gains tax of 30%. You can use the funds you have built up to invest into a property in Spain via a UK company with the Swedish company holding preference shares to match the investment amount.
It looks like you have two seperate issues to solve, the corporate structure to make the future potential sale more appealing to investors by using a holding company setup with the swedish company being used for the EU side and a UK company for the UK (non-EU). You would also include a 3rd entitiy to import from China and resell on to the Swedish & UK entities with your management cost being covered in this new entitiy. All three under the holding company. You can even invest the funds accumulated via investment companies to buy property which you can use and/or rent out to try out a few different countries before changing your residency. Your personal tax residency is the 2nd issue but it's only an issue if you personally want to take a salary and dividend to 'personally' own poperties. You have a lot of flexibility inside a multi-jurisdiction corporate structure to buy properties, boats, cars etc. Instead of holidays you have business trips, it's a different mindset but the last thing you want to own things in your personal name. You want to control things not own them, on paper this means you don't have to pay income and captial gains tax etc. Change a family holiday into a business trip with a board meeting with all expenses paid by one of the companies and you'll have the lifestyle you want without the massive personal tax bills. You can still pay yourself the same salary you are now to continue contributing and pay off any debts you personally have plus cover the personal expenses you can not deduct from your group of companies. As you learn how to use different setups and become more comfortable using different jurisdictions, you'll also naturally expand the business into other areas.
You may be correct if the companies are setup with one shareholder and one director, as this can be considered just an 'alter ego'.
I'm interested to know how turning on a laptop and replying to a load of emails etc creates 'Permanent Establishment'?Ok, then you don't have management and control in Sweden, but you'd most likely still have permanent establishment.
Sweden also has strict CFC laws which would allow Sweden to tax the companies if they don't pay enough tax.
Also for obvious reasons, he wants to keep 80% in the company or what its was and not reduce his ownership to 10-30% or something like that.
There is no need to pierce any corporate veil. It's called permanent establishment, look it up.
Tax Alert: Swedish Tax Agency makes sharp turn on home office driven permanent establishments
By a newly released statement the Swedish Tax Agency makes a sharp turn and significantly alter their view of when an individual’s home office should be at the disposal of the foreign employer.www2.deloitte.com
www.sovereigngroup.com
That is why we are all here... it's what makes us smarter every day.
I actually just remembered something else. I've heard that there are two tax exemptions in Sweden called the 6-month and the 1-year rule.
I don't remember the details, but if you work abroad and you have to be abroad to work and you don't work from Sweden and you only spend up to 70 days per year or so in Sweden - then you don't have to pay tax on that employment income in Sweden. This in the domestic law, so it doesn't require a tax treaty, so it should work even with the UAE.
This is explicitly intended for cases where you are otherwise tax resident in Sweden, e.g. because you have a home in Sweden.
Might be worth checking out.
