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Comment by mishaker

2 years ago

I was e-resident too but had to become resident in Estonia. Cause if you are abroad and distribute yourself dividend (as a sole entrepreneur) your host country would consider your Estonian company local and thus it constitutes a permanent establishment and that becomes extremely complicated

Of course--but this is the case for almost all jurisdictions of record vs jurisdictions of taxation. Few countries want to allow a company to operate 100% in their borders without extracting some degree of taxation. (In fact, this is basic OECD taxation doctrine.)

My situation is complex, but, generally, the advantages of Estonian registration are found in drastically simplified and lower-cost business registration and processing (vs say a GmbH in Germany or Switzerland with high share capital and accounting costs) or ease of operation for digital nomads or fully remote companies. A OÜ isn't for everyone in every life situation, but when it fits, it tends to work really well.

A LLC or C Corp in the US could work just as well (or better), depending on the situation.

  • Just to clarify: since you are only an e-resident of Estonia, are all your three Estonian companies paying the corporate income tax (CIT) in your personal country of residence?

    Since Switzerland is currently the only country in Europe without CFC rules[1], it seems that an Estonian company can only be managed from Estonia or Switzerland without being considered as local for tax purposes in another jurisdiction.

    [1] https://taxfoundation.org/controlled-foreign-corporation-cfc...

    • From my last post:

      > My situation is complex

      This means my situation pretty much does not apply to anyone else, and the tax residency question is very complex in my case, as well. I won't bore you with details. :)

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