Blog – Expatriation and Residency in Paraguay
Taxation of stateless persons: who taxes them, ...
Stateless persons: 4-15 million people without nationality. 1954 Convention = tax equality with nationals. De facto fiscal statelessness (nomads) = a trap: France taxes by default. Paraguay = solution: residency...
Taxation of stateless persons: who taxes them, ...
Stateless persons: 4-15 million people without nationality. 1954 Convention = tax equality with nationals. De facto fiscal statelessness (nomads) = a trap: France taxes by default. Paraguay = solution: residency...
Country-by-Country Reporting (CbCR): what multi...
CbCR (Country-by-Country Report): Multinationals with revenues of €750M+ declare income, profits, taxes, and employees by country. Your US LLC with €200k is 1500 times below the threshold. No direct obligation....
Country-by-Country Reporting (CbCR): what multi...
CbCR (Country-by-Country Report): Multinationals with revenues of €750M+ declare income, profits, taxes, and employees by country. Your US LLC with €200k is 1500 times below the threshold. No direct obligation....
Transfer Pricing for Small Structures: What Fre...
Transfer Pricing: designed for multinationals but (theoretically) applicable to your US LLC. Art. 57 CGI, arm's length principle, 5 OECD methods. Low risk if PY resident + regular distribution +...
Transfer Pricing for Small Structures: What Fre...
Transfer Pricing: designed for multinationals but (theoretically) applicable to your US LLC. Art. 57 CGI, arm's length principle, 5 OECD methods. Low risk if PY resident + regular distribution +...
Tax treaties: how they work, what they're for, ...
Tax treaty: agreement to avoid double taxation, reduce withholdings, and resolve residency conflicts (tie-breaker). France has 130 of them — not with Paraguay. Why this is NOT a problem: territoriality...
Tax treaties: how they work, what they're for, ...
Tax treaty: agreement to avoid double taxation, reduce withholdings, and resolve residency conflicts (tie-breaker). France has 130 of them — not with Paraguay. Why this is NOT a problem: territoriality...
OECD Pillar 1 and Pillar 2: The Future of Inter...
Pillar 1 (redistribution of digital giants, 100 companies, stalled) and Pillar 2 (minimum tax 15%, multinationals $750M+, underway). No impact for expatriates in Paraguay. 5 future trends, 3 10-year scenarios,...
OECD Pillar 1 and Pillar 2: The Future of Inter...
Pillar 1 (redistribution of digital giants, 100 companies, stalled) and Pillar 2 (minimum tax 15%, multinationals $750M+, underway). No impact for expatriates in Paraguay. 5 future trends, 3 10-year scenarios,...
Tax haven vs. legal optimization: where's the l...
Legal optimisation (green zone) vs. tax avoidance (grey zone) vs. fraud (red zone): precise legal boundary. Abuse of rights Art. L.64/L.64 A, jurisprudence, 5 red lines. Real expatriation to Paraguay...
Tax haven vs. legal optimization: where's the l...
Legal optimisation (green zone) vs. tax avoidance (grey zone) vs. fraud (red zone): precise legal boundary. Abuse of rights Art. L.64/L.64 A, jurisprudence, 5 red lines. Real expatriation to Paraguay...
The 183-day rule worldwide: a comparison of tax...
183 days ≠ tax residency. France: principal home takes precedence over days. Germany: one residence is sufficient. Belgium: national register. USA: citizenship. Paraguay: no day threshold. 25 countries compared, real...
The 183-day rule worldwide: a comparison of tax...
183 days ≠ tax residency. France: principal home takes precedence over days. Germany: one residence is sufficient. Belgium: national register. USA: citizenship. Paraguay: no day threshold. 25 countries compared, real...
CFC rules: understanding controlled foreign com...
CFC rules (art. 123 bis CGI): France can tax the undistributed profits of your US LLC — but ONLY if you are a French tax resident. In Paraguay (no CFC...
CFC rules: understanding controlled foreign com...
CFC rules (art. 123 bis CGI): France can tax the undistributed profits of your US LLC — but ONLY if you are a French tax resident. In Paraguay (no CFC...
Tax rulings: how some countries negotiate tailo...
Tax rulings: Swiss lump-sum taxation (CHF 250k-1M/year), Italian flat tax (€100k/year), Greek flat tax (€100k + €500k investment). Reserved for ultra-high-net-worth individuals, limited duration, risk of abolition. Paraguay offers 0%...
Tax rulings: how some countries negotiate tailo...
Tax rulings: Swiss lump-sum taxation (CHF 250k-1M/year), Italian flat tax (€100k/year), Greek flat tax (€100k + €500k investment). Reserved for ultra-high-net-worth individuals, limited duration, risk of abolition. Paraguay offers 0%...