Best Country for Trading (Tax efficiency)
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@Daal : No one needs a degree (hopefully) to understand that if a company is managed and controlled from Brazil then it's a Brazil resident company therefore liable to taxes in Brazil.
However why don't you just link those laws that states what you said?
[/QUOTE]
I linked the article that clearly said that the government was trying to close a loophole in which people could open offshore companies and only pay tax in the amounts that were transfered to them. It was called MP 627, which was then changed by Congress and turned into Lei 12.973/2014. All the sections that related to people holding offshore companies were removed. That only things that stood was when a brazilian company owns an offshore company (in a tax advantaged country). In that case there is some kind of change.
The article (as well as the opinion of the tax experts I consulted), clearly states that in the current system you only pay tax in the amounts distributed.
Here is another Article from a lawfirm
http://blog.angelicoadvogados.com.br/2014/04/01/offshore-fora-da-mira-do-leao/
the title says 'offshore outside the lion's target'. Lion is the nickname of the tax revenue service
This section clearly states that you can legally defer taxes using this system
"Assim, para as pessoas físicas, acabou por se manter o regime que posterga a tributação para o momento da efetiva distribuição do lucro da pessoa jurídica estrangeira (regime de diferimento)."
However why don't you just link those laws that states what you said?
[/QUOTE]I linked the article that clearly said that the government was trying to close a loophole in which people could open offshore companies and only pay tax in the amounts that were transfered to them. It was called MP 627, which was then changed by Congress and turned into Lei 12.973/2014. All the sections that related to people holding offshore companies were removed. That only things that stood was when a brazilian company owns an offshore company (in a tax advantaged country). In that case there is some kind of change.
The article (as well as the opinion of the tax experts I consulted), clearly states that in the current system you only pay tax in the amounts distributed.
Here is another Article from a lawfirm
http://blog.angelicoadvogados.com.br/2014/04/01/offshore-fora-da-mira-do-leao/
the title says 'offshore outside the lion's target'. Lion is the nickname of the tax revenue service
This section clearly states that you can legally defer taxes using this system
"Assim, para as pessoas físicas, acabou por se manter o regime que posterga a tributação para o momento da efetiva distribuição do lucro da pessoa jurídica estrangeira (regime de diferimento)."
@Daal: Honestly, I don't understand anything of the website you linked but now I'll check this deeply, in-detail. If this is the case then I'll move to Brazil this year 
However I still doubt if it's true because this would means that anyone can incorporate a company outside of Brazil and can legally avoid taxes on local sourced income not just on trading.
However I still doubt if it's true because this would means that anyone can incorporate a company outside of Brazil and can legally avoid taxes on local sourced income not just on trading.
@Daal : Sir, you're wrong.
Source: http://rsmi.com/publications/border-crossing/488-brazil-changes-to-brazilian-cfc-rules.html
You HAVE to pay taxes if you own and control an offshore company in most cases.
Quote:
Individuals
The Brazilian individual, who is the controlling shareholder of a foreign company, will have to pay income tax on the respective profits as they are accrued, in the following cases:
Source: http://rsmi.com/publications/border-crossing/488-brazil-changes-to-brazilian-cfc-rules.html
You HAVE to pay taxes if you own and control an offshore company in most cases.
Quote:
Individuals
The Brazilian individual, who is the controlling shareholder of a foreign company, will have to pay income tax on the respective profits as they are accrued, in the following cases:
- The foreign controlled company is subject to a tax regime where the corporate income tax rate is lower than 20%.
- The foreign controlled company is located in a low-tax jurisdiction or benefits from a privileged tax regime.
- The individual does not have the documentation related to the incorporation of the company, duly registered with the appropriate authorities, identifying the other shareholders.
NO. This was the changes PROPOSED by MP 627, which were REJECTED by CONGRESS. how many times will I have to tell you that? MP stands by 'provisional measure', is the same as a bill being proposed by Obama just to get it changed or shutdown by Boener. The final LAW had nothing at the level of people owning offshore entities, only brazilian companies had new laws passed
here is what happened to mp 627
http://www.planalto.gov.br/ccivil_03/_ato2011-2014/2013/Mpv/mpv627.htm
notice that almost everything has a dash on it? thats because it no longer exists
You claim that you have accounts in 20+ countries but you are ready to move to a country like Brazil tomorrow if it offers you tax free trading ? Like it's a difficult proposition outside the usual suspects ( ie northern hemisphere industrialised countries, including probably Australia) ??
uh ?!?
@luisHK : Wouldn't you move to a country where you could legally defer taxes forever? Personally I would plus it's really easy to get a residence permit in Brazil.
You can have bank accounts in any number of countries but you still have to pay taxes based on your residence.
@Daal : Ok, I'll check this with KPMG later today.
You can have bank accounts in any number of countries but you still have to pay taxes based on your residence.
@Daal : Ok, I'll check this with KPMG later today.
I wouldn't move to Brazil except maybe if threatened with immediate and acute pain, but find it not very difficult to trade tax free (again outside the usual suspects).
As of trading through offshore corporation, it should work in most/all countries that don't tax overseas income, it is quite difficult for a tax department to know about the shareholding and directorship of such companies, even more about the amount and nature of the profits and where the day to day management is happening, and the less develloped an economy the less tooth its tax department has.
If you really have accounts in 20+ countries and are used to trade trough intricate structures to manage your assets discreetly as you claim you should already know about all this.
As of trading through offshore corporation, it should work in most/all countries that don't tax overseas income, it is quite difficult for a tax department to know about the shareholding and directorship of such companies, even more about the amount and nature of the profits and where the day to day management is happening, and the less develloped an economy the less tooth its tax department has.
If you really have accounts in 20+ countries and are used to trade trough intricate structures to manage your assets discreetly as you claim you should already know about all this.
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@luisHK : I have many bank accounts because of personal reasons. Regardless of the number of accounts you have you're liable to taxes. I'm not an exception so I pay the taxes; - sadly.
You're wrong. From January 1, 2017 the country of your residence will know all your offshore accounts, companies, trust and foundations. Why? Because of the international information exchange agreement proposed by OECD. It has been accepted by every single country. So, for instance if you live in HK and you have a bank account on your name, under a company name, trust, etc. then the bank will report that you have a bank account there and your balance as well. So actually from 2017 it will be really easy for those territorial basis taxation countries to tax you.
You're wrong. From January 1, 2017 the country of your residence will know all your offshore accounts, companies, trust and foundations. Why? Because of the international information exchange agreement proposed by OECD. It has been accepted by every single country. So, for instance if you live in HK and you have a bank account on your name, under a company name, trust, etc. then the bank will report that you have a bank account there and your balance as well. So actually from 2017 it will be really easy for those territorial basis taxation countries to tax you.