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Globe-Trotting
Sportsman Or Entertainer: Eastern Europe
An Eastern European citizen with extensive,
international, multi-sourced income is not
in a good tax situation unless he or she
can establish non-residence, since full,
world-wide taxation of income and capital
gains will apply.
If resident in Eastern Europe, the peripatetic
professional may well find himself paying
withholding tax in a number of countries
which cannot in some cases be reclaimed
or set off against local taxation because
of the absence of a tax treaty.
Such an individual will almost certainly
resort to corporate structures to market
his or her skills and manage derivative
income flows. It may well be that these
can usefully be based in offshore jurisdictions,
although complex structures may be necessary
if corporate anti-avoidance rules are to
be avoided.
Apart from the extra difficulty of minimising
tax on the income side, an Eastern European-resident
sportsman or entertainer will be in the
same position as any other Eastern European
resident. (Select 'High-Tax Country Resident'
and 'Eastern Europe' for a fuller description).
If a foreign sportsman or entertainer becomes
resident in Eastern Europe, then he or she
is in the same position as an expatriate
executive (select 'Expatriate Executive'
and 'Eastern Europe').
Such individuals who have significant business
income may be able to make use of offshore
corporate tax shelters in order to minimise
Eastern European taxation.
Virtually all Eastern European countries
have double taxation treaties with Cyprus
and Malta, themselves both having offshore
tax regimes. This oddity results from arrangements
made by the Former Soviet Union, and it
will often be the case that foreign business
arrangements or the receipt of foreign-source
income is best arranged through intermediary
companies in Cyprus or Malta.
www.lowtax.net
contains details of the offshore business
sectors of 35 jurisdictions, and their taxation.
NB: The suggestions given above do not
constitute investment advice. They are intended
only to assist individuals in finding appropriate
professional advice, which is essential
for anyone planning offshore investment.
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