General description
We want to move 2 software developers to Bulgaria so they live and work from there permanently.
2 families: 1st family - 4 persons (2 children), 2nd family - 2 persons
Initial situation:
• there are 2 companies controller by the same persons. Ukrainian Ltd and German GmbH
• Most of the customers work with German company, but there still some turnovers in Ukrainian one
• Financial compensation for the work of these 2 developers will be provided both from German and Ukrainian companies. It has to be flexible. Form of this financial compensation (salary, freelancers honorars) is not important
• While providing services to German company this developers will either improve standard software product belonging to German company or indirectly provide services for the customers of German company outside of EU. Services provided to Ukrainian company are always intended for customers outside of EU (probably important for VAT)
• In the future it should be possible to hire new employees in Bulgaria (probably in new separate company or as freelancers)
• German company can pay freelancers honorars to any account in any country providing it is confirmed that account belongs to intended person or company
• Actual salaries of these two employees are considerably larger than average salary in Bulgaria
Goals:
• Residence permit in Bulgaria (with the option to get permanent residency in 5 years)
• Legal way to provide consulting services to German and Ukrainian companies
• Minimizing tax load while remaining completely legal
• Avoid losing amounts paid (and not compensated) as VAT on Bulgarian side
• Immediate or future option to found local company and employ these 2 persons there
Important note: we’ve tried to describe initial situation independently from our current knowledge about possible solution option. We would like to receive suggestions of the possible implementation schemes that optimally support our goals.
Possible initial solution according to our current knowledge:
• Ukrainian company opens trade representative office and Bulgaria and sends these 2 employees there
• Ukrainian company ensures part of the necessary compensation as salary for trade office employees. At the same time they have direct consulting contracts with German GmbH which compensate the rest of their salaries
• In the long term Bulgarian company (limited) is founded and they become employees of this company (this should a final goal, we’d like to understand when and under which circumstances it’s going to be possible)
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