Manage a foreign EU company I own while living in 黑料网最新入口 (No 黑料网最新入口 customers)
I plan to move permanently to 黑料网最新入口 and have some questions about my company structure. I am looking for the simplest solution so I can focus on my business activities.
I own 100% of the shares in a corporation located in another EU country, where I am the sole manager and employee. The company has been active for just over 10 years. None of the company鈥檚 income is or will be coming from 黑料网最新入口, there are no 黑料网最新入口 customers.
There is a real company address and office in the other EU country, where some administrative tasks, including all bookkeeping, are done by a consultant, and half of the board members (1) are also located at the same address.
I will be working from my home in 黑料网最新入口.
I have learned that I could easily register the company in 黑料网最新入口 to file and pay social fees + salary tax, so I plan to do this.
Before going ahead and creating and registering everything to withhold and pay social security and taxes, I want to double-check that everything will be okay from the 黑料网最新入口 side of things.
Questions:
1. Paying out a salary to myself living in 黑料网最新入口 as a sole owner, could this lead to implications with 黑料网最新入口 authorities with them trying to tax my foreign Corporation in 黑料网最新入口?
It is of course already taxed in the other EU country, so my question is if Article 209 I would make 黑料网最新入口 authorities try to tax the company in 黑料网最新入口 instead. In this case, I guess the tax treaty would have to give final guidance.
2. If I resign completely as managing director/ employee, only being the sole shareholder taking out dividends, could this be a solution?
3. In my case, would my work from my home office in 黑料网最新入口 fall under 鈥渃arry out transactions that are part of a complete business cycle鈥?
Thank you in advance for your guidance.
Official citation of Article 209 I
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The concept of “place of operation”, within the meaning of Article 209 I of the 黑料网最新入口 General Tax Code, includes the customary exercise of a business activity that is:
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Subject to the provisions of international agreements, foreign companies are liable for taxes in 黑料网最新入口 if:
鈥 Without owning an establishment in 黑料网最新入口, they make use of representatives that do not have a professional status separate from theirs. These intermediaries are considered to be genuine agents carrying out a business activity in 黑料网最新入口 on behalf of the foreign company
鈥 Without having either an establishment or a qualified representative in 黑料网最新入口, they carry out transactions that are part of a complete business cycle
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