Company will end up as tax resident from the country where it is managed & controlled .
If there is an DTA the tie breaker rule applies and the country from where it is managed & controlled gets the right to tax .
Also you get to enjoy bureaucracy+ dual accounting in both countries .
If there is no DTA it can lead to double taxation .
And if you don't have a fixed place of management/business+ tax residency (basically nomading) a US LLC disregarded for tax purposes is a much better fit .
What do you wish you had known before getting started?
Your yearly financial data is public, everyone will know your income / profit. And you will get spammed, your email will be public too. How easy has it been to run the company remotely?
Great Have you ever needed to travel to Estonia to resolve an issue?
Only visited once to open bank account LHV but I closed it since then and can use remote banking Looking back, would you do it again?
YesFrom: https://learn.e-resident.gov.ee/hc/en-gb/articles/3600007215...
> Corporate tax residency
> However, some countries have different rules for deciding if a company is tax resident. It is common that, in addition to the place of incorporation, the place of effective management can trigger tax residence. If you run your company from a country with regulations like this, then the company may end up having dual tax residence. This happens when two states believe that the company is tax resident in their jurisdiction and will want to tax the company’s profits.
This 'It is common that [...] the place of effective management can trigger tax residence' is indeed common.
Also, shameless plug for people broadly interested in the country of Estonia and how it became a leader in e-gov/tech only a generation after independence from the Soviet Union, I wrote a book about it after being curious myself! https://www.rebootinganation.com/
See https://www.e-resident.gov.ee/understanding-cross-border-tax..., look for “Permanent Establishment”
I’m using UK myself. It takes a few forms and half a day to get a working Wise/Stripe account.
Honestly, I’d avoid the EU in general. There are only about four or five good places to set up a company and stay connected to the financial system: the US, especially Wyoming or Delaware, Dubai, Singapore, and Hong Kong.