Gediminas said:
In my eyes Estonian company is not the best option. Standard corporate income tax rate in Estonia 20% and dividends are taxed at 14%. The only difference is that Estonia taxes profit when it is distributed, i.e. paid in the form of dividends or whatever other form. Then they charge 20% plus 14% (dividend withholding tax). They do not allow to take money from Estonian company so easy paying them to Delaware company. At least they will require to prove that such Delaware company has an office, employees and proves that these services were actually provided. US also recently introduced branch tax which is, as a general rule, also applicable to Delaware companies.
I think much better would be to set up Dutch partnership (it is not subject to tax as long as it does not carry any activities within the Netherlands) or Maltese (5% CIT), Cypriot company (it is possible to reduce CIT to 2.5%). In any case much more circumstances should be taken into account in order to find the best solution.
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