LLC for Greek Resident
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Ansolutely. But why does it take me that many messages to get an answer from you:
Do you think it is polite to ignore me 9︌ times? I am trying to help you getting busted by IRS and you treat me︍ like this?
You could have saved us and you a lot of bs by just︎ answering it the first time I asked.
Do you think it is polite to ignore me 9︌ times? I am trying to help you getting busted by IRS and you treat me︍ like this?
You could have saved us and you a lot of bs by just︎ answering it the first time I asked.
Sure - thank you and sorry for this 🙂
Just not have the unlimited time .
As I said, we think either manager from US (CPA told us if its a part-time freelancer manager - e.g. works 1-2 hours per day then it doesn't create ECI. Other solution is a manager from EU or last solution a member-managed.
Just not have the unlimited time .
As I said, we think either manager from US (CPA told us if its a part-time freelancer manager - e.g. works 1-2 hours per day then it doesn't create ECI. Other solution is a manager from EU or last solution a member-managed.
If he manages the company from the US, you will pay personal income tax in the US. See here from the IRS
You will need a director in Monaco in order to pull this off. Or in a place without any PE rules. But honestly, this is not a very good way to avoid taxes. You may set up a company in Malta or somewhere and pay 5% tax. And then another 5% on the dividends. This will give you less troubles in the long run.
You can get a director from a country like Panama, Paraguay, Seychelles, Bahrain, Qatar, ... basically some country that doesn't enforce PE rules (we have a thread about such countries somewhere).
But I don't see how Greece would accept that as proper substance.
The US manager is the worst idea because you risk that both the US and Greece would try to tax the company.
But I don't see how Greece would accept that as proper substance.
The US manager is the worst idea because you risk that both the US and Greece would try to tax the company.
Yes, and in the worst combination:
- personal income in the US
- dividend income in Europe
Well, if you can get around paying the other part, yes.
But just for your understanding for the normal case with real companies:
But in the general case with a US manager, you would be taxed in the US personally. What you then want is to be taxed in Greece again personally. Because then the DTA takes effect and you only pay no tax in Greece as already paid in the US. If Greece would tax it like an︀ opaque company, you end up paying more.
That is the general case. And now, you︁ will also understand what the problem on the Greek side is. Greek taxes dividends for︂ something that previously has been taxes as a company elsewhere. But if your company has︃ not been taxed anywhere due to the lack of a PE anywhere, you will most︄ likely face a tax audit sooner or later. And then, you will end up paying︅ a whole Greek corporate tax.
The whole thing is quite risky in your case. You︆ can apply for a tax ruling or take the risk. But as I mentioned above,︇ you are better off with a Malta, Cyprus, Bulgaria company with low tax and then︈ 5% in Greece.
But just for your understanding for the normal case with real companies:
But in the general case with a US manager, you would be taxed in the US personally. What you then want is to be taxed in Greece again personally. Because then the DTA takes effect and you only pay no tax in Greece as already paid in the US. If Greece would tax it like an︀ opaque company, you end up paying more.
That is the general case. And now, you︁ will also understand what the problem on the Greek side is. Greek taxes dividends for︂ something that previously has been taxes as a company elsewhere. But if your company has︃ not been taxed anywhere due to the lack of a PE anywhere, you will most︄ likely face a tax audit sooner or later. And then, you will end up paying︅ a whole Greek corporate tax.
The whole thing is quite risky in your case. You︆ can apply for a tax ruling or take the risk. But as I mentioned above,︇ you are better off with a Malta, Cyprus, Bulgaria company with low tax and then︈ 5% in Greece.
How do you conclude that one only needs to pay dividend tax in Greece when a US LLC makes a profit? Are the Greeks less strict than the rest of the EU? With that in mind, I’d like to ask: how can anyone believe that the Greek tax authorities would accept having some random McDonald's employee as the management of your US LLC, thereby claiming substance and avoiding personal taxation?
Or what is the purpose of the US LLC? Is it perhaps not intended to conduct business but only to hold assets?
I don’t understand it.
Or what is the purpose of the US LLC? Is it perhaps not intended to conduct business but only to hold assets?
I don’t understand it.
I think the main problem is that the management is effectively in Greece. There is just a freelancer somewhere claiming to be the director.
Congrats to your Lifetime!︀
From reading all the discussion. My personal opinion is that OP had a smart idea.︁ Which probably would have worked some time ago. But I doubt how solid the tax︂ hiding is these days. I like the creativity of OP. But I have doubt that︃ it will work.
While we are at it. The often quoted no CIT for Monaco︄ here:
https://monentreprise.gouv.mc/en/th...x/other-taxes-and-duties/corporate-income-tax
It says that if over 25% of your revenue is foreign, you are︅ subject to 25% of tax. Hence, I guess running a US LLC from Monaco would︆ not work on paper.
From reading all the discussion. My personal opinion is that OP had a smart idea.︁ Which probably would have worked some time ago. But I doubt how solid the tax︂ hiding is these days. I like the creativity of OP. But I have doubt that︃ it will work.
While we are at it. The often quoted no CIT for Monaco︄ here:
https://monentreprise.gouv.mc/en/th...x/other-taxes-and-duties/corporate-income-tax
It says that if over 25% of your revenue is foreign, you are︅ subject to 25% of tax. Hence, I guess running a US LLC from Monaco would︆ not work on paper.
Thank you! Please to help OCT!
The fact is that what you’re describing here applies if one hides their original activity and location and pretends to have a company that isn’t what it claims to be. That’s why I’m asking, as it’s incredibly︀ confusing that someone with such an aggressive tone demands proof and documentation that personal taxation︁ doesn’t apply in Greece or Germany when owning a US LLC that is openly operated︂ from Greece or Germany, with the sole purpose of avoiding taxes. The rules are the︃ same across the EU, there isn’t much to doubt.
Or what do you believe is︄ different in this case?
The fact is that what you’re describing here applies if one hides their original activity and location and pretends to have a company that isn’t what it claims to be. That’s why I’m asking, as it’s incredibly︀ confusing that someone with such an aggressive tone demands proof and documentation that personal taxation︁ doesn’t apply in Greece or Germany when owning a US LLC that is openly operated︂ from Greece or Germany, with the sole purpose of avoiding taxes. The rules are the︃ same across the EU, there isn’t much to doubt.
Or what do you believe is︄ different in this case?
Sorry, I am now not 100% sure which side you are now standing on.︁
I personally think that if you operate a US LLC from Greece with a fake︂ director anywhere, and do not pay any taxes anywhere but only 5% dividend tax in︃ Greece, the Greek probably won't buy the story. At least they will ask for documentation︄ of the "declared" dividends, which you won't be able to produce as the profits have︅ never been taxed, let alone been entered into any book keeping system and reported anywhere.︆
And at least then, they will ask where the company has had its management and︇ then tax it in Greece.
Such games work for @JustAnotherNomad and @peter taradash even the︈ PT is a myth as they don't declare any tax anywhere. But if you want︉ to declare it in Greece, I think there will sooner or later be questions that︊ simply cannot be answered.
I personally think that if you operate a US LLC from Greece with a fake︂ director anywhere, and do not pay any taxes anywhere but only 5% dividend tax in︃ Greece, the Greek probably won't buy the story. At least they will ask for documentation︄ of the "declared" dividends, which you won't be able to produce as the profits have︅ never been taxed, let alone been entered into any book keeping system and reported anywhere.︆
And at least then, they will ask where the company has had its management and︇ then tax it in Greece.
Such games work for @JustAnotherNomad and @peter taradash even the︈ PT is a myth as they don't declare any tax anywhere. But if you want︉ to declare it in Greece, I think there will sooner or later be questions that︊ simply cannot be answered.
Yes. @troupos13 with all due respect. I like your creativity. But I am pretty confident that your plan will not work in a proper way.. The main problem is that for the declaration of dividends, you will be lacking the profit tax bill from the other country. It may work for a while, but in my opinion is not worth the risk.
There are ways to reduce tax, but those would all involve either leaving Greece or hiring directors abroad in a place of low taxation. Malta would be worth looking into. Such setups︀ mainly make sense for more than 200,000 USD per year as below you waste too︁ much on legal and setup fees.
There are ways to reduce tax, but those would all involve either leaving Greece or hiring directors abroad in a place of low taxation. Malta would be worth looking into. Such setups︀ mainly make sense for more than 200,000 USD per year as below you waste too︁ much on legal and setup fees.
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