Mexican Tax Resident with Online Agency - Looking for a structure that works.

Hi all - Canadian citizen looking at a move to Mexico with 2 dependents. I have a small digital-only business selling into Canada & US. Looking for a structure that will minimize Mexican tax. Here's what I've come up with so far - any feedback and suggestions appreciated...

• Operating company in Malta - bills clients in US & Canada and accepts payments
• Foreign parent for Maltese operating company to claim 6/7 rebate on corp tax paid to Malta
• Self-employed in Mexico - bill Maltese Co for enough services to pay some living expense bills in Mexico

Some of my questions so far:

1. Does this structure make sense - is there a way to set this up with reasonable expectation of success?
2. Should the foreign parent be a company...or perhaps a trust or foundation?
3. What country would best home for the foreign parent?
4. Banking - where would be best to set up (bank & jurisdiction) and will I have trouble setting that up for Maltese Co or foreign parent?
5. Would it make sense to use an EMI?
6. Where along the way will I run into UBO problems?

Hoping I've provided enough background and questions to allow for suggestions.

Thanks in advance.

Thanks Martin - I appreciate the feedback. To recap, the structure makes sense in theory, but in reality I would likely not be able to get banking to go along with it. And, you're saying I would be on the wrong side of CFC and anti-avoidance rules. Is there a structure and jurisdiction(s) I could look at that would allow me to get banking and maintain anonymity?

Martin Everson said:

Firstly Mexico has CFC rules and anti-avoidance rules also. The structure you propose is to derive a tax benefit which goes against anti-avoidance rules.

Makes sense but slim chance of success

Company as a trust would make it unbankable for small time business.

I take it parent company is just for Malta 6/7 rebate purposes. So any country where its cheap to setup and manage one.

You got Canadian, living in Mexico with Malta trading company with maybe a UK parent company. Basically unbankable sadly.

If you can find one to support this structure.

What type of problems you thinking about?

I had originally replied at bottom of thread but perhaps I should have replied here (directly to you). Let me know if this notifies you.

Thanks Martin - I appreciate the opinion and the advice. I believe I noticed that you 'liked' an interview with New Era Offshore. Any thoughts on their approach?

Martin Everson said:

I don't know them but they offer an interesting approach. Someone willing to take the time to explain what it is they do it always welcome in my books.

I hear you - he does seem to have a unique way of exploiting that hole in the system and it's great to have someone go on the record.
Will report back anything I can learn from him.
Cheers!