A company abroad is not a universal answer. For a smaller business with local clients, the cost of an office, a director and administration overseas often eats up the expected saving. It makes sense where there is a genuine cross-border reason: a holding before a sale, separating intellectual property, expanding into other markets or a licence available only in a particular country. Where no such reason exists, we will advise you to stay with a Slovak limited company.
We compare two or three suitable countries, such as Cyprus, Malta, Estonia, Bulgaria, the United Arab Emirates or Delaware. We propose the type of company and a plan for real presence abroad. Incorporation and local administration are handled by vetted partners in the target country, while we run the project and the Slovak side: CFC, DAC6, exit tax, transfer pricing and the public sector partner register. We do not set up classic offshore entities or anonymous structures.
Council Directive (EU) 2016/1164 (ATAD) and the Slovak CFC rules in Section 17h of the Income Tax Act target companies with no genuine economic substance. Under Section 3(6) of the Slovak Tax Procedure Code, the tax authority may disregard a structure that exists only to obtain a tax advantage.
A foreign company managed from Slovakia may become Slovak tax resident under Section 2(d)(2) of the Income Tax Act. Key decisions must therefore be taken in the target country.
Our fees do not include fees and costs in the target country, such as registration, office, director or accountant. We quantify them once the jurisdiction is chosen.
Articles are in Slovak.
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In a consultation we assess your situation, suggest a way forward and tell you what costs to expect.
€90 incl. VAT, 30 minutes, in person or online
This page is for general information, reflects Slovak law at the time of writing and is not a substitute for advice on your particular matter.
