bypass 30 percent withholding tax for royalties
- Thread starter FrustratedMan
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The only thing i'd like to add is that RIGHT NOW the US-USSR treaty is unidirectional so US still obeys to the old USSR treaty (which includes Georgia).
The problem is that Georgia doen't recognize that treaty as valid from its part since the treaty is with USSR and not with Georgia so when they will decide to negotiate a new treaty with US you can forget about not having LoB in the treaty and having 0% WHT on royalties.
This is exactly what happened to Kazakhstan when︀ renegotiated a new treaty with US.
Now they have 10% US WHT on royalties.
If you want to exploit that loophole you have to physically move to Georgia because Georgia︁ has 0% US WHT on royalties AND foreign sourced income is tax free (for natural︂ persons).
By moving there you can enjoy your royalties tax free but since you said︃ that the treaty country must be UK for some reason I assume this strategy isn't︄ a viable solution for you.
The problem is that Georgia doen't recognize that treaty as valid from its part since the treaty is with USSR and not with Georgia so when they will decide to negotiate a new treaty with US you can forget about not having LoB in the treaty and having 0% WHT on royalties.
This is exactly what happened to Kazakhstan when︀ renegotiated a new treaty with US.
Now they have 10% US WHT on royalties.
If you want to exploit that loophole you have to physically move to Georgia because Georgia︁ has 0% US WHT on royalties AND foreign sourced income is tax free (for natural︂ persons).
By moving there you can enjoy your royalties tax free but since you said︃ that the treaty country must be UK for some reason I assume this strategy isn't︄ a viable solution for you.
I'm willing to look for other options.
But that's︀ for the future, correct?
If I don't move there and open a company there as︁ a non-resident will that still be doable, as in getting rid of the 30 percent︂ withholding tax?
But that's︀ for the future, correct?
If I don't move there and open a company there as︁ a non-resident will that still be doable, as in getting rid of the 30 percent︂ withholding tax?
Yes, that's correct.
When i said "just pay 19%" i assumed that UK company would qualify for treaty benefits so the US WHT on royalties would be zero.
If the UK company wouldn't qualify for treaty benefits what i said before stands.
When i factored in the 5% Georgian WHT on dividends for some reason i assumed dividends would be send to UK but unless OP shares more about why UK has to be the treaty country and where he is︀ tax resident i could only speculate.
When i said "just pay 19%" i assumed that UK company would qualify for treaty benefits so the US WHT on royalties would be zero.
If the UK company wouldn't qualify for treaty benefits what i said before stands.
When i factored in the 5% Georgian WHT on dividends for some reason i assumed dividends would be send to UK but unless OP shares more about why UK has to be the treaty country and where he is︀ tax resident i could only speculate.
Depends on the average balance he plans to have in the bank, if @FrustratedMan gives more details I can recommend
Do you know if a HK ltd with a Latvian ubo and resident will have to pay 30 percent in withholding taxes or Latvia’s rate of 10 percent?
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