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tax solution for small business (30K profit)

Yes it is a very stupid and not safe solution like all non-legal solutions but particularly this one as UBO reportings etc are the norm and will be the norm everywhere and then it is no sleep time. Nominees will never protect you, rather rip you off.

Move your butt means relocate yes and follow the law. The only way in the EU right now if you ask me. If you want to play the game you need to follow the rules. No shortcuts or you will very very likely regret it someday and with the advances in EU law that will be very soon either way.
 
I do understand, don't worry about anything. I appreciate the time people spend to give me valuable information from their experience.

To give you an idea what we are facing here, last year I was talking to my Greek accountant. For 10K business profit (before tax and various health/pension/social security), it would leave just 1.500 euros net profit.

Tax laws are changing to the better though.
 
what a bad advice. a simple tax lawyer consulation in the US will cost him more than the taxes he pays at home. establishing a US tax nexus and effectively connected income / connection to the US is the absolut last thing you ever want to do except for very very few very high stakes reasons. just outright dangerous advice apart from the fact that the intent is probably to evade income tax and not declare in his home country... just stupid all around
 
To give you an idea what we are facing here, last year I was talking to my Greek accountant. For 10K business profit (before tax and various health/pension/social security), it would leave just 1.500 euros net profit.

Then speak to your accountant and see how much and what expenses you can deduct legally to lower your overall effective tax rate. So i.e see if there is any tax deductible corporate pension contributions (i.e cash fund held inside a pension plan) you can make etc.
 
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CFC is not the issue. Greece requires that a CFC has at least 30% passive income which wouldn’t be the case. The issue is permanent establishment/effective place of management. My fingers are becoming sore from having to type this. I don’t know which idiot started spreading these CFC bulls**t rumors, it’s really annoying.
Hello

Please allow me to ask and learn...

If there is no passive income, the foreign company is not considered CFC?

The effective management will be in Greece though, this will show up on an audit. So it will be taxed in Greece, even if it is not CFC? See what I am missing here?
 
Hello

Please allow me to ask and learn...

If there is no passive income, the foreign company is not considered CFC?

The effective management will be in Greece though, this will show up on an audit. So it will be taxed in Greece, even if it is not CFC? See what I am missing here?
Hi,

The tax regime in Greece is killing Greek businesses as far as I know. We have a lot of Greeks in Cyprus so I think if you speak eith your accountant in Greece and get connected to a Cyprus advisor/accountant you would probably be in a better position to understand when and if you should set up your business in Cyprus and how this would be best structured.
 
If there is no passive income, the foreign company is not considered CFC?

Correct - as far as my understanding of Greek tax law goes.

The effective management will be in Greece though, this will show up on an audit. So it will be taxed in Greece, even if it is not CFC? See what I am missing here?

Yes, exactly. CFC laws are not the only way they can tax you. If the company is managed from Greece, it will be taxed as a Greek company.
 
Correct - as far as my understanding of Greek tax law goes.


Yes, exactly. CFC laws are not the only way they can tax you. If the company is managed from Greece, it will be taxed as a Greek company.

The above does not make sense to me.

The Greek CFC laws are 4172/2013 and 4174/2013. These are the laws that state that when the effective management is from Greece, then the company will be taxed as if it was Greek. These laws also state that this applies only for passive income companies.

So could you please elaborate?
 
I don't speak Greek, so I can't tell you where exactly this is written. But it is about corporate tax residence and permanent establishment:

The purpose of CFC rules is just to "catch" setups that would not be covered by other rules. It is very common for them to only apply to passive income companies, because such companies require little substance.
If it's an operative business that is run from Greece, then other laws already cover this in detail, so it's not necessary for CFC laws to apply to them as well.
 
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