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RobertGibson Offline

Beiträge: 7

27.01.2023 08:37
Management office & Substance Antworten

Material matters are becoming increasingly difficult for tax purposes in Europe and globally, therefore some clients may prefer a stronger physical presence at the place of exercise than virtual office services. One of the possible strategies for increasing substance is the establishment of a functional office. Content issues usually arise when local tax authorities require confirmation that the company's operations are taking place in the country where the company is registered: they want to see that commercial activity actually exists in the specified jurisdiction.

A company of substance is a company abroad that resembles a classic “offshore” company but has what is called “substance” (presence), i.e. a business, in other words – an administrative office. It's more like a real local company but has ties to the onshore business.

For more and more entrepreneurs, the economic substance of their company is becoming too much for them. Creating economic substance has become quite the gamble as tax authorities, banks and government institutions delve ever deeper into the two main questions: 'Where is the real place of governance and control of the company?' and 'Who is the beneficial owner?'

Confidus Solutions can offer Substance Office in various jurisdictions worldwide including numerous famous offshore jurisdictions. However, considering the complexity and efficiency of content delivery, we would strongly recommend considering the following jurisdictions as your first choice: Latvia, Cyprus, Lithuania and Hungary - as we can offer more advanced services in these states instead of just a virtual office, as well more solid reasons to believe that the company operates in the specific location. The question of the actual place of management and control of the company has recently become not only for tax authorities, but also for business partners, suppliers, banks and opponents due to the implementation of interstate tax legislation and the rapid development of international trade and online trade of crucial importance.

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Administrative office in Cyprus
Administrative office in Latvia
Administrative office in Bulgaria
Importance of economic substance
Establishing economic substance in a registered jurisdiction can be critical to verification by local tax authorities. However, the process of creating substance must be carefully evaluated beforehand, as under certain conditions it can run counter to your initial goals and business structure. The substance needs to be addressed in order to avoid a higher tax burden on your business and to avoid major tax disputes with your tax authority.

Corporations have relied on “offshore” or non-resident structures for many years to reduce or defer taxes and improve returns for investors. This is particularly popular with private equity and real estate structures. But increasingly, and particularly within the EU, tax authorities are demanding more if the reason for tax non-resident status and/or local tax exemption is to be given. Usually "more" is interpreted as having more substance and physical presence in the indicated jurisdiction.

Today there are still many structures that are set up in such a way that there is what is known as double non-taxation, meaning that there is no effective tax levied in either country on the total proceeds generated within the structure. The primary goal is to prevent the granting of treaty benefits to international corporate structures that are only geared to the advantageous conditions of the applicable double tax treaty.

When there is an advantage in having a substance
Having substance is an advantage if you are contemplating the formation of an offshore or onshore entity and want the highest possible protection in terms of recognition by international and local tax authorities. To avoid problems, your international corporate structure must be set up as an actual and "real" corporate structure.

Based on the actual role the company plays in your worldwide structure, there must be a relevant level of "real" activity. In practice, this means, for example, that the registered office of the company should not be the same as that of hundreds of other companies and the director of the company should not be the director of hundreds of other companies at the same time. That means your company address should at least be unique and the managing director should have a real function in the company.

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