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Where to live with max 0-5% total tax

God is watching your words ange¤%&
I'm not saying that to show off.

in Romania the employee gets 55% out, the rest 45% goes to the gov, tax, health insurance etc.

Tax on profit 10%
Tax on dividends 5%
And it's added the health insurance if you didn't have one payed.

Roads and others, we pay $to the UE, we could get more than what we pay, but politicians don't like "free" $ from UE 'cause they get caught, so no new hospitals, highways etc, at least till last November, now we have half of the gov with new politicians and things are running, kinda unbelievable comparing with other times!!!

A couple of times I asked myself the same, does it worth going all the hasle for that 5%, for the moment it's an idea, I still check the legal and practical part of it.


The main problem is the banking system, they avoid crypto or they have silly limits like under 20k $ per month.
 
I'm not saying that to show off.

in Romania the employee gets 55% out, the rest 45% goes to the gov, tax, health insurance etc.

Tax on profit 10%
Tax on dividends 5%
And it's added the health insurance if you didn't have one payed.

Roads and others, we pay $to the UE, we could get more than what we pay, but politicians don't like "free" $ from UE 'cause they get caught, so no new hospitals, highways etc, at least till last November, now we have half of the gov with new politicians and things are running, kinda unbelievable comparing with other times!!!

A couple of times I asked myself the same, does it worth going all the hasle for that 5%, for the moment it's an idea, I still check the legal and practical part of it.


The main problem is the banking system, they avoid crypto or they have silly limits like under 20k $ per month.
Open a revolut or binance account, and you are done! Easy peasy :)

Also the romanian corporate tax should be 16% but, you can pay as little as 3% up to 1 Million €, which can be further reduced if you employ someone. Which is not that bad at all! I'm reading this conversation because I'm thinking myself to move from Italy to Romania to open the microcompany there and benefit from these tax exemptions. If you want to stay close to Europe, Romania is one of the best, if not the best ever!

In the past few months I studied about many possibilities and the most attractive if you don't want to go on the other side of the world, keep your costs and taxes low and still have the freedom to travel, in my opinion are these ones:

  1. LLP Uk + Dubai residency = zero tax rate and should be legal (someone can confirm that is 100% legal to own a UK llp company which is tax transparent while being resident in Dubai, without breaking any rules?), but a bit expensive living there.
  2. Portugal residency + Maltese company + maltese Holding = 5% tax rate, but very expensive because you need office, employees and local director plus 2 companies = trading + holding. Seems quite expensive and complicated.
  3. Romania company + Romania residency = 3% tax rate on total turnover but only 1% if you have an employee + 5% on dividends.
  4. Bulgaria company + Bulgarian residency = 10% tax rate on profits + 5% on dividends. More or less same issues and advantages like in Romania about the car, the social contributions, etc, but here I won’t understand anything about Bulgarian language. I think Romanian language is easier). Both Romania and Bulgaria come with these advantages plus: they are both also quite cheap to setup and maintain and to create the "substance" you need if you want to relocate somewhere else in Europe later. You can also rent or buy a car from your company and use to to move within Central Europe. (They have the 183 days rule, but I've been told, it's really hard that someone will check about that (can someone confirm about this?)
  5. Cyprus company + Cyprus residency (12.5 tax rate (19.500€ tax exemption on personal level) but many social contributions and high accountancy/setup expenses + it seems to me also high level of complication regarding the book keeping). 4.5k company setup. + 1.5/2k annual accountancy. This could be good for the 60 days rule, but in fact you have to rent a place the whole year, prove you don't spend 183 days in any other country, and pay social contributions and health national taxes. Plus to get the personal residence, you have on of these options: 1. to register a local company, 2. being employed in a local company or 3. register yourself as self employed, while proving you have some reason to do so (active contracts, income) and paying the taxes accordingly which are much higher).
  6. Andorra company + Andorra residency 10% tax rate but more expensive

To me it seems that if you want to stick around europe and have pretty much flexibility the best solutions are these two:

1) LLP Uk with UAE Residency (then if you want to you can live in Europe 10 months a year (but not in the same country).
It's more expensive but worth considering. The problem is that renting an apartment if you are not living in Dubai is like wasting 10k a year.

2) Company setup in Romania and Bulgaria, with local residency. Cost much less and you are still free to move around europe (and also you have a car to do so if you want to). The main disadvantages are the capital gains taxes (which don't apply in Malta, Cyprus, Dubai and I think also Gibraltar).

But in this case, once you get a local employee, you can also choose to relocate elsewhere later, with pretty much the same benefits:
- Malta (zero tax rate)
- Portugal (zero tax rate)
- Greece (2.5 tax rate)
- Dubai (zero tax rate)
- Other places with a bit more higher taxes (but only if you distribute dividends, if not it's not an issue)

Ofc if you don't mind to relocate in Asia or South America, there are certainly far better solutions than these ones.

But it's worth leaving everything behind like that, just to save on taxes?

Maybe it is, but since i'm not ready for that big move now, I believe these could be the best possibile setup, while I will decide where to settle in the near future, let's say in 2/3/4 years from now.

Maybe I missed something... For example many talks good about Estonia, but I don't understand how you can avoid to pay the 20% on dividends.

Which is in your opinion the best setup, to live with very low tax rates, low fixed costs, without the need to change your company structure or loose your benefits if you move yourself to another country, be free to travel almost anywhere and whenever you want (for example you can live 5 months in Barcelona and 5 months in Paris, while being resident in Bucarest or Sofia) and also have a car if you want to?


Please let me know what do you guys think about this!
 
Maybe the Estonian company scheme could work when you are getting a salary instead of dividends, while being resident in Portugal or Malta? Could this work to get a zero (or almost zero) legal tax scheme? And it is a good solution?
 
Maybe the Estonian company scheme could work when you are getting a salary instead of dividends, while being resident in Portugal or Malta? Could this work to get a zero (or almost zero) legal tax scheme? And it is a good solution?

Yes, Yes and Yes for Malta
 
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Yes, Yes and Yes for Malta
So I can be non dom resident in Malta and own the Estonian company and get the salary from it (zero tax rate), while being resident in Malta and paying zero tax rate on my foreing income? Are you sure about that? From the Estonian side, this seems fine, but if I'm residing in Malta even as non dom, i guess I will trigger the place of effective management rules, if I don't have a local director in Estonia.

Am I right?


Salary​

Normally an Estonian company is liable to withhold 20% personal income tax (PIT) and apply 33% social tax on salary payments for work performed physically in Estonia. Unemployment contribution of 1.6% is withheld and 0.8% applied to the gross salary.

If the work, however, is not physically performed in Estonia, then no Estonian PIT nor Estonian social tax or unemployment contributions apply to salary payments as these are not considered to be sourced in Estonia. The income is taxable in the state of residence of the employee.

If you have a non-resident employee who does not work physically in Estonia, then you don’t have to report anything to the employee register. However, payments made to non-residents must be declared on tax return TSD Annex 2.
 
So I can be non dom resident in Malta and own the Estonian company and get the salary from it (zero tax rate), while being resident in Malta and paying zero tax rate on my foreing income? Are you sure about that? From the Estonian side, this seems fine, but if I'm residing in Malta even as non dom, i guess I will trigger the place of effective management rules, if I don't have a local director in Estonia.

You need to get salary paid offshore and not remitted to Malta or you will be taxed on the salary. If you don't remit it to Malta and you are not resident in Estonia you pay no tax on your salary.

The Estonia company will be considered a CFC in Malta and treated as such but you have the following exception or threshold:

The CFC rule shall not find application in relation to an entity or permanent establishment:

  1. with accounting profits of no more than EUR 750,000 and non-trading income of no more than EUR 75,000;
 
You need to get salary paid offshore and not remitted to Malta or you will be taxed on the salary. If you don't remit it to Malta and you are not resident in Estonia you pay no tax on your salary.

The Estonia company will be considered a CFC in Malta and treated as such but you have the following exception or threshold:

The CFC rule shall not find application in relation to an entity or permanent establishment:

  1. with accounting profits of no more than EUR 750,000 and non-trading income of no more than EUR 75,000;
yes about CFC you are right, but without a local director in Estonia, you are not breaking the POEM (place of effective management) rule?
 
yes about CFC you are right, but without a local director in Estonia, you are not breaking the POEM (place of effective management) rule?

Did you read what I said. The Estonia company can be a CFC with PE but as long as you don't meet the threshold the Estonia CFC will not be taxed.
 
So the POEM apply only when the CFC is triggered?

Place of effective management and control would be Malta for an Estonian company owned by a director resident in Malta. So whats your point?
 
Ah okay, but unless you distribute any dividends there are no issues?

No

The company would be tax resident in Malta?

This is established by Article 5 of of DTA signed between Malta and Estonia. You need to check your specific case and business model.

Would the salary still be tax free if paid by a company that is tax resident in Malta?

See the above response and check your specific case.
 
You need to get salary paid offshore and not remitted to Malta or you will be taxed on the salary. If you don't remit it to Malta and you are not resident in Estonia you pay no tax on your salary.

The Estonia company will be considered a CFC in Malta and treated as such but you have the following exception or threshold:

The CFC rule shall not find application in relation to an entity or permanent establishment:

  1. with accounting profits of no more than EUR 750,000 and non-trading income of no more than EUR 75,000;
instead as regards remittance basis.

if I work with the offshore and I exceed 35k, do I have to declare and then pay 5k?

or working offshore is it better not to say anything to the Maltese state?
 
You need to get salary paid offshore and not remitted to Malta or you will be taxed on the salary. If you don't remit it to Malta and you are not resident in Estonia you pay no tax on your salary.

The Estonia company will be considered a CFC in Malta and treated as such but you have the following exception or threshold:

The CFC rule shall not find application in relation to an entity or permanent establishment:

  1. with accounting profits of no more than EUR 750,000 and non-trading income of no more than EUR 75,000;

There is also the problem about the POEM (place of effective management) which you should take care of.

If you are the solo director and owner of this company; and you have no office, no employees, but just a shell company in Estonia, in theory i think you are gonna trigger this rule and Malta can say your company is managed there and you should pay taxes accordingly.
 

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