@din Indeed, you shouldn’t have any issues moving to Malta as an EU citizen. I assume you’d just be “ordinarily resident” in Malta.
Regarding taxation, the crucial part of the statement you quoted is if you’re a nomad. Since you’ll most likely be non-Domiciled in Malta you only pay local tax on income earned locally (meaning anything you earn while you are traveling outside Malta is excluded) and income earned elsewhere that you remit to or spend in Malta.
If you take out more than €35,000 in salary + dividends in a given tax year (no matter if earned outside and not remitted to Malta), you’ll have to pay a €5,000 minimum tax to Malta. For income earned during the time spend in Malta the regular progressive Maltese tax rates apply, but there are some quite high tax-free quotas that you can avail yourself of. The first €9,100 paid for work in Malta is completely tax-free (assuming you’re unmarried), with progressive rates up to 35% above that.
If you pay, say, €2,000 in taxes for your Maltese source (meaning earned while physically in Malta) income, and earn more than €35,000 globally, you’ll pay another €3,000 in taxes so that you pay a minimum of €5,000 to Malta. You wouldn’t pay another €5,000 for a total of €7,000, since the tax already paid in Malta is deducted.
With an Estonian company, you have the benefit of controlling how much you pay yourself in a given year, meaning that in most years you could pay yourself less than the €35,000 limit and potentially pay no tax (depending on how much time you spend in Malta). Then every so often you can pay yourself as high a salary as possible and pay the €5,000 minimum tax in those years only.
@Chandra_Melo Do you have NHR status in Portugal? That’s a prerequisite to avoid all or most taxes in Portugal with a similar setup. You’d also need to be mostly nomadic. If you’re living most of the year in Portugal the NHR would only really help you pay zero tax in Portugal on passive income (dividends), not earned income (salaries).
On the other hand, since you’re still tax resident in Brazil this may not work for you at all. Since even though Portugal wouldn’t tax certain income it doesn’t mean Brazil wouldn’t tax the same income.
So most likely you’d have to:
- Be registered as a non-habitual resident in Portugal
- Stop being fiscally resident in Brazil
- Be nomadic most of the year, not perform most of your work in Portugal
If these are not applicable to you I wouldn’t bother with a company in Estonia for your circumstances.
For both of you @Chandra_Melo & @din, if you were to spend the bulk of your time in a given country (Portugal or Malta) and manage the Estonian company there, you may run into an issue with the Estonian company becoming tax resident there (unless you’re note actually managing the company yourself, but have employees that do that). In that case it would simply be easier to have a local company.