Company will end up as tax resident from the country where it is managed & controlled .
If there is an DTA the tie breaker rule applies and the country from where it is managed & controlled gets the right to tax .
Also you get to enjoy bureaucracy+ dual accounting in both countries .
If there is no DTA it can lead to double taxation .
And if you don't have a fixed place of management/business+ tax residency (basically nomading) a US LLC disregarded for tax purposes is a much better fit .
I never needed to visit since I could use Wise for banking.
The only thing is that surprised me was the tax rate, when I created my Company the advertised rate was 20/80 but in reality it was ~25/75 and it increased since.
UK, USA and Singapore are the popular choices for this. UK is simple and cheaper, Singapore is a bit more expensive. I don’t see a reason to go USA route unless you are seeking investment from there.
I’m using UK myself. It takes a few forms and half a day to get a working Wise/Stripe account.
Finally somebody who knows their stuff. I never understood why people preferred Estonian incorporation given that it's almost certainly more expensive and less convenient than the other options.
> However, some countries have different rules for deciding if a company is tax resident. It is common that, in addition to the place of incorporation, the place of effective management can trigger tax residence. If you run your company from a country with regulations like this, then the company may end up having dual tax residence. This happens when two states believe that the company is tax resident in their jurisdiction and will want to tax the company’s profits.
This 'It is common that [...] the place of effective management can trigger tax residence' is indeed common.
Hence the executives/boardmembers-all-fly-to-some-island (Jersey is the one in my mind), have board meeting in the airport, sign the papers, and all fly home?
Company stays "in" Jersey, none of the humans need to live there?
That is unfortunately not how it works. Most commonly the place from which decisions are made on a day to day basis is used. This results in the country in which 50% or more of your directors reside for 183 days a year.
So if 50% or more of your directors spend 183 days per year in the UK then your Estonian based business becomes UK tax resident in the eyes of the UK.
Do not underestimate the complexity of these rules.
It has been a great experience. Setting up the company was online, and it took 3 days, including the time spent to change the name because the initial name was rejected. You can use Wise for banking, but LHV is also visible but there is an account limit if you don’t live there. Accounting is easy, but you will need an accountant for tax reporting if you have a VAT ID. My accountant charges me 60 euros per month and does an amazing job.
Any tips for a 2 person European company. One founder based in Amsterdam, the other in London. We are close to setting things up, some input from other founders would be great
It was great until they turned racists and stopped me from using the service because of my nationality (Russia), even though neither me or the business had anything to do with Russia.
At the consulate, I emphasized that I was opening a company in Estonia to support the economy and country, especially because of the threat they're facing off against. Demonstrating one's deep knowledge of the situation, and fully backing Estonia in spite of the magnitude of the threat, is the way to win friends.
I can't speak about all EU countries, but the one country I looked into (Spain), I couldn't find a way to do everything remotely. It required being physically present for some things, so that's why I am asking about whether Estonia actually delivers IRL on the e part of e-residence.
I think banking is still the biggest issue if you’re not an Estonian resident.
Honestly, I’d avoid the EU in general. There are only about four or five good places to set up a company and stay connected to the financial system: the US, especially Wyoming or Delaware, Dubai, Singapore, and Hong Kong.
Useless + overhyped .
Company will end up as tax resident from the country where it is managed & controlled .
If there is an DTA the tie breaker rule applies and the country from where it is managed & controlled gets the right to tax .
Also you get to enjoy bureaucracy+ dual accounting in both countries .
If there is no DTA it can lead to double taxation .
And if you don't have a fixed place of management/business+ tax residency (basically nomading) a US LLC disregarded for tax purposes is a much better fit .
Username checks out.
I was surprised how amazing it is ?
Your yearly financial data is public, everyone will know your income / profit. And you will get spammed, your email will be public too. Great Only visited once to open bank account LHV but I closed it since then and can use remote banking YesSame experience for me, it's been great!
I never needed to visit since I could use Wise for banking.
The only thing is that surprised me was the tax rate, when I created my Company the advertised rate was 20/80 but in reality it was ~25/75 and it increased since.
Wise is not a bank.
UK, USA and Singapore are the popular choices for this. UK is simple and cheaper, Singapore is a bit more expensive. I don’t see a reason to go USA route unless you are seeking investment from there.
I’m using UK myself. It takes a few forms and half a day to get a working Wise/Stripe account.
Finally somebody who knows their stuff. I never understood why people preferred Estonian incorporation given that it's almost certainly more expensive and less convenient than the other options.
Please beware:
From: https://learn.e-resident.gov.ee/hc/en-gb/articles/3600007215...
> Corporate tax residency
> However, some countries have different rules for deciding if a company is tax resident. It is common that, in addition to the place of incorporation, the place of effective management can trigger tax residence. If you run your company from a country with regulations like this, then the company may end up having dual tax residence. This happens when two states believe that the company is tax resident in their jurisdiction and will want to tax the company’s profits.
This 'It is common that [...] the place of effective management can trigger tax residence' is indeed common.
Hence the executives/boardmembers-all-fly-to-some-island (Jersey is the one in my mind), have board meeting in the airport, sign the papers, and all fly home?
Company stays "in" Jersey, none of the humans need to live there?
That does not work necessarily work in the UK anymore.
That is unfortunately not how it works. Most commonly the place from which decisions are made on a day to day basis is used. This results in the country in which 50% or more of your directors reside for 183 days a year.
So if 50% or more of your directors spend 183 days per year in the UK then your Estonian based business becomes UK tax resident in the eyes of the UK.
Do not underestimate the complexity of these rules.
Also estonian law doesn't recognize trusts, so if you want to save your assets for your children that's a problem.
You mostly use foundations for that purpose in civil law countries (which are also not part of the hague trust convention )
https://news.ycombinator.com/item?id=47500239
It has been a great experience. Setting up the company was online, and it took 3 days, including the time spent to change the name because the initial name was rejected. You can use Wise for banking, but LHV is also visible but there is an account limit if you don’t live there. Accounting is easy, but you will need an accountant for tax reporting if you have a VAT ID. My accountant charges me 60 euros per month and does an amazing job.
Where are you located? Where will you administer the company from? That impacts your tax situation quite a lot.
See https://www.e-resident.gov.ee/understanding-cross-border-tax..., look for “Permanent Establishment”
I am in the US currently, would be managing initially from the US. I understand there will be US tax complications, but I can/would deal with those.
The worst thing you could do as an us citizen (I assume ) and resident is to incorporate outside of the US.
This is a terrible idea. please hire a professional with direct experience on these matters and not blog posts from influencers
Any tips for a 2 person European company. One founder based in Amsterdam, the other in London. We are close to setting things up, some input from other founders would be great
It was great until they turned racists and stopped me from using the service because of my nationality (Russia), even though neither me or the business had anything to do with Russia.
russian is not a race.
are you a russian speaking estonian? or russian citizen?
Russian citizen living abroad
That's understandable (and predictable), considering russia's aggressive stance regarding the Baltics.
At the consulate, I emphasized that I was opening a company in Estonia to support the economy and country, especially because of the threat they're facing off against. Demonstrating one's deep knowledge of the situation, and fully backing Estonia in spite of the magnitude of the threat, is the way to win friends.
If you are Russian, you have something to do with Russia
I switched to 1Password after the last one.
Question: are OÜs particularly beneficial even for non-Estonians (EU), and in what way?
I can't speak about all EU countries, but the one country I looked into (Spain), I couldn't find a way to do everything remotely. It required being physically present for some things, so that's why I am asking about whether Estonia actually delivers IRL on the e part of e-residence.
I think banking is still the biggest issue if you’re not an Estonian resident.
Honestly, I’d avoid the EU in general. There are only about four or five good places to set up a company and stay connected to the financial system: the US, especially Wyoming or Delaware, Dubai, Singapore, and Hong Kong.
London post-Brexit is problematic outside of the legacy stuff in City of London, but why not Dublin?
Why not London/UK?