Blah, blah, blah, PWC, blah, blah, PWC, PWC, blah, blah, blah. When are you going to quit that namedropping, cause it gets awfully boring. The facts are that PWC wasn't able to advise you, because you didn't fully disclose your situation. Only after I pointed that out to you and posted a ruling by the Supreme Court you started taking the Dutch route serious. You can twist and turn all you like, but these are the facts. You're just too small of a man to admit it. Your attitude towards me and the Dutch people is really appalling, but still you 're gonna move to awful, backward Holland to save a few bucks. What poverty!
Right! That's why come back again and again after you supposedly put me on ignore twice and wrote to me in PM that you would leave ET. When can we expect your next response? 2 days, 3 days? Or should we continue in Dutch? Then it won't be so hard for you to reply. Keep coming back and i'm going to expose your true character and make you look totally ridiculous even more.
@Hittfeld I would like to know that also. However I trade currencies, 3-4 trades a day, highly leveraged positions.
Me too, would like to know what's happening in the Netherlands as I am planning moving there and just started leaning the language. Here in Brazil, you pay 20% for daytrades and 15% for holding a position more than a day on your gains. Brokers provide good leaverage (you can also keep you maney in savings account or even buy interest rates notes and use it as garantia for you day trades, so + 16% in a year (inflation was 11%) but bad liquidity for the futures market ( and these are the more liquid marquets compared to stocks). Taxes are paid by yourself up to the end of next month. If you have a loss in one month you can offset in the next month or even years to come, not a problem. Just to be more specific, the liquidity in the ibovespa index and Real/dollar futures are not that bad, it just can't compare to the ES liquidity, and I'm talking intraday here. And YES if you open an offshore company you only pay taxes if you bring money back to Brazil, and I know that's for sure as I have a friend who has a company and also trades in foreign markets. No need to ask a lawyer. So good tax, not that good liquidity if trading localy and all the shit that comes in the pac when you live in a friking sewage full of crimes and corruption. Unless you are one of the creatures that like and benefit from being corrupt and like living around fences with bulett proof cars (not joking) this may not be a place for you, believe me. Of course you can get prostitutes for cheap if that's what you looking for. Sorry, I'm just not proud of my country. Ditch....Everywhere you may find stupid people (even here) but also the good people may benefit from the knowledge you shared in these and other posts, I am one of those. Please keep posting.
I would love to see this in practice. What you and your local friends misunderstand is the difference between what's allowed and what's so unimportant that the authorities doesn't care. What I want to point out is yes, you may be able to get away with using an offshore company and drawing a salary as long as you don't make significant profits. However I would love to see the tax man's face when you say that the company is yours, you control it from Brazil, it doesn't pay corporate tax in Brazil on its Brazil sourced income but you just bought a brand new Bentley and a $5 million mansion from your salary and you really enjoy flying first class but you don't have much time to talk about all this because your $50k Rolex shows that you have to go. Got it? So you might be able to get away with an offshore structure despite it's clearly and obviously tax evasion in this case. The reason why this works for you is that you don't make much profits and OECD hasn't yet began the automatic exchange of information. You don't have a Bentley bought with your salary paid by your offshore company, you don't have a huge home and you don't spend $50k a month. Once you do this then trust me, you will quickly understand two things: corporate tax residence and controlled foreign company. Happy New Year!
Of course you would face problems, you bought a mansion it means you had to bring back money somehow, and if you broght in your pocket or somebody broght to you that's for sure not following the law. The law says money wire only and pay the tax please. If you have properties or cars boats etc you must declare it, tell where the money came from and pay the taxes, just like any other country i gess, lots of people dont do it, I mean LOTS, but thats againt the law. As for bringing a car from outside you pay more than 100% in taxes. If you have a salary outside Brasil and bring it in you are only waved if it's less then 20 thousand reais a year wich is 5 thousand dollars... or if the country you work for has agreement on double taxation and in this case you were already taxed in the other country. But if you want to keep most of the money in your offshore company so that you can make it grow bigger, as somebody said before, without being slashed by taxes you can do it legally. So to answer your question straight there is no corporate tax residence and controlled foreign company as it does in Europe. Corporate tax for offshore companies are taxed differently than the local company tax wich are taxed every year. The offshores only when repatriated gains. There is no tax evasion nor money evasion as you should declare on your tax returns the money you sent out and the gains you bring in. There is a law in Brazil that somebody published the link in one of the posts before, it regulates offshore companies, they tried to change that but i gess most of the politicians have their own offshore ghost companies, so did not get approved. Also Company tax are 34% and that would be paid only when money is repatriated so i think is not woth it, you can just open a trading account outside Brazil and be taxed the same as trading locally and only when drawing money in. So 34% againt 20%. It's just like buying some medium term investment that expires in three years, you only pay taxes when it expires in this case 24%.
If you do buy all of those things with after tax profits (from the salary) why would the tax man have any issues Your statements are just flat out wrong. Not only this is contradicted by tax attorneys (who are paid to research the law) but also by the executive order issued by the president trying to close this loophole in 2014, which was then changed and some parts shutdown by the brazilian congress (who benefit from the loophole). The OECD is a joke, they create GUIDELINES, the law is something different. That law trumps guidelines everytime
What you fail to comprehend is that CFC was created in 2014 (it did not exist before that) in Brazil for BR companies owning offshore entities. Individuals do not have CFC rules. That was explicitly removed from the bill by congress in 2014