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Companies abroad and change of tax residence

JZTL firm provides services and assistance in establishing companies abroad (Czech Republic, Malta, Cyprus, England, Georgia, Estonia) and offshore companies (including Anguilla, Bahamas, Barbados, Belize, British Virgin Islands, Cayman Islands, Mauritius, Saint Kitts and Nevis, Panama, Samoa, Seychelles, Saint Vincent and the Marshall Islands). We help in opening bank accounts abroad (Switzerland, Monaco).

We provide services in the field of changing a Polish tax residence. A tax residence means an unlimited tax liability, which covers all the income achieved by the taxpayer, regardless of where (in which country) it was obtained. We help our Clients change their Polish tax residence to Cypriot, Maltese and Estonian.

Cyprus – On July 14, 2017, the Cyprus Chamber of Deputies adopted a statutory amendment to the definition of “natural person resident in Cyprus” in accordance with the Income Tax Act, from January 1, 2017, a person who: spends no more than 183 days in any one country during a tax year; is not a taxpayer from another country in the same tax year and meets the following three conditions:

  1. Stays in Cyprus for at least 60 days in a tax year;
  2. Conducts business in Cyprus or is employed in Cyprus or has a position in a Cypriot legal entity at any time during the tax year;
  3. Maintains a permanent home in Cyprus that he/she owns or rents;

he/she may be considered a Cyprus tax resident.

In contrast, the Maltese legal system allows obtaining one of four types of tax residences (temporary residence, ordinary residence, long-term residence and permanent residence). Among them, the most advantageous solution for tax optimization purposes is ordinary residence, i.e., regular residence. A resident taxpayer pays income tax only on income obtained from sources located in Malta and from sources located outside Malta, in the event that this income is transferred to Malta.

The subject of changing tax residence is even more important in the context of taxation of income obtained outside of the country of residence through the so-called controlled foreign companies (so-called CFC regulations) and the CRS system – exchange of information on bank accounts.