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For how long it will be recurring and what is the amount ?

anotherDev said:

Alright here is my situation. Tax resident in Greece. Living in Greece and 3 other EU countries ( including Swiss, not a tax resident there ). Looking to accept a substantial crypto payment for software development. My problem is my Greek Llc can't accept cryptos cause the tax agency is allergic. I am wondering what options I have. I would just pay the local corp tax but it looks “impossible”. Options till now:

1) Figure out a way to invoice via a subsidiary and pay the Greek corp tax.
2) Setup a Cy company and take advantage of ip box regime”¦ But what about substance.
3) Try to change tax residency to some place with minimum stay requirements?

Any ideas ?

Should mention the invoice will be recurring for quite some time

I do not know what you exactly mean by (1) but my idea would be:
I. Establish a company B in some crypto-friendly jurisdiction and invoice your client from there (hopefully the client would be OK with this, as I guess from your post)
Then
IIa.
Pay the corporate tax in this country and take the rest as dividends (and pay personal tax in Greece, if applicable)
IIb.
Invoice this company from Greece LLC and pay corporate tax in Greece
or
IIc.
Use this situation for making more tax optimization for the Company B (7 figures might be worth it) :) (I am not a real expert re:this)

P.S.
Yes, it can happen that Greek taxmen will make a conclusion that Company B is directly liable for Greek taxes as it is managed from Greece; but it would not trouble you, as I understand. The trick is that Greek taxmen (or Greek insitutions in general) are not entitled to decide whether Company B can deal with crypto or whatever, it's not their business. They can be interested only in the gross profit...

Last edited: May 5, 2024

anotherDev said:

Thanks for your reply.

You are welcome.

anotherDev said:

Basically to clarify few things. Corporate tax in Gr is 22.5% and div tax is 5%. I am happy to pay this and get over with it without any “optimisation” trouble. Paying income tax though would raise it to 44% which is a big no.

All fully understandable.

anotherDev said:

So I am trying to decide how to approach. How can I invoice that company from Greek LLC?

As any other company, basically :) Just take care that the pricing is not insane in any way, not to induce a suspicion that you are doing some very shady things ”“ what you aren't.

anotherDev said:

Could I invoice my Cyprus company all the amount it's receiving

Well, let there something for the operational costs ;). Yes, and probably some 8-10% (you can take it as dividends afterwards); again, not to attract some unnecessary attention.
Remark: I have never checked how it is with crypto and CY ”“ I hope that there are no or almost no problems, not as in GR.

anotherDev said:

and get taxed in my country ?

I am not familiar with GR laws; but why not?

anotherDev said:

Tax optimisation is quite worth it in terms of numbers but I am unsure if it's worth it in terms of headaches.

Well, this is wisely said, definitely.

anotherDev said:

Time for me to deploy the hardest part of the equation then. What if I would like to speculate on the crypto payment coins. Eg: I am paid in Sol, but I want to hold that sol for longer period because I think it will go higher in price. Issue here is that the Greek Llc can't hold any cryptos as well (lol).

So what? The Company B will hold all the crypto ”“ as long as you wish. And the Greek LLC will invoice it ... when it's time :)

Just a side-note: You have mentioned Cyprus as possible incorporation place of a new company ”“ why not; but I presume that you are aware that a CY company is not from the cheapest, especially as of the substance ”“ which you actually do not need. There are more favourable jurisdictions for your case, I guess.

anotherDev said:

My problem is my Greek Llc can't accept cryptos

How would anyone know the crypto address is a Greek LLC and not personal?
What am I missing here?

jafo said:

What am I missing here?

:) As far as I understand, @anotherDev wants/needs to have these earnings in his LLC's accounting (he is even ready to pay taxes ;) ) and GR taxmen simply do not like crypto and are not able/willing to handle it.
Correct, @anotherDev?

anotherDev said:

Basically the situation in Greece is as follows. Crypto don't exist. You can't declare crypto earnings neither in the personal or corporate level. If you declare crypto earnings ( and pay the tax ) assuming it's capital gains, in a potential audit your tax will get reverted with a response “this income can't get declared”. This doesn't mean that crypto is tax free though. Cause if you buy some house given that you can't explain your wealth since it can't get declared you get fined 80% ( there are newspapers articles with cases of this ). Similarly you can't accept crypto payments (with a potential fine of 2x the amount you invoiced, since it's not part of the banking system and it could fall in the cash clause).

OMG. (Is it just to laugh or more likely to cry?)

anotherDev said:

Knowing this situation I am trying to orchestrate a way to bypass this situation while still remain legal.

I understand fully. Do you think that the solution discusses above can work? I do; however I must admit that I am not familiar with the Greek environment which is, as I see, specific ;).

anotherDev said:

TLDR: Trying to pay tax but can't

It's even worse, I must say...

anotherDev said:

Basically the situation in Greece is as follows. Crypto don't exist. You can't declare crypto earnings neither in the personal or corporate level. If you declare crypto earnings ( and pay the tax ) assuming it's capital gains, in a potential audit your tax will get reverted with a response “this income can't get declared”. This doesn't mean that crypto is tax free though. Cause if you buy some house given that you can't explain your wealth since it can't get declared you get fined 80% ( there are newspapers articles with cases of this ). Similarly you can't accept crypto payments (with a potential fine of 2x the amount you invoiced, since it's not part of the banking system and it could fall in the cash clause). Knowing this situation I am trying to orchestrate a way to bypass this situation while still remain legal.

TLDR: Trying to pay tax but can't

They make it a bit difficult for themselves in Greece. Considering their economic situation, they should have embraced Crypto like Switzerland, for example, has done. They could have gained big from it and perhaps attracted people with a lot of money!"

US LLC... etc.... pass through entity.

anotherDev said:

Banking would be challenging in this case. Are there banking options for US LLCs that will accept crypto related transactions ?

Yes, they are ”“ it has been discussed here very recently, search for it. Just out-of-the-box I can name Zen and Verifo but there are more...