Broker for CY / Dubai residents
- Thread starter bigbite100
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He could set up a company in Romania for the sole purpose of holding US equities. See my post here: Romania micro company not worth it anymore?
The DTAA does not contain a LOB clause and the WHT on dividends paid out to Romanian tax residents is only 10%. It might also be possible to credit the WHT paid in the US against Romanian corporate tax.
However in this case I would suggest using some kind of an IBC combined with Romanian corporate tax residency. Not sure if I would want to trust the Romanian legal system ns2
Last edited: May 15, 2023
But then you'd have Romanian withholding tax on top of that.
Though it seems like you could reduce it to 0 with a UAE holding company:
https://taxsummaries.pwc.com/romania/corporate/withholding-taxes
But by then you'd have such a complicated setup that you'll probably pay a ton for accounting and compliance, on top of Romanian corporate income tax...
If you get a lot of dividends from the US, you'd probably be better off with some US-centric setup like a trust.
Though it seems like you could reduce it to 0 with a UAE holding company:
https://taxsummaries.pwc.com/romania/corporate/withholding-taxes
But by then you'd have such a complicated setup that you'll probably pay a ton for accounting and compliance, on top of Romanian corporate income tax...
If you get a lot of dividends from the US, you'd probably be better off with some US-centric setup like a trust.
Correct. However, that could could be avoided thanks to the EU parent-subsidiary directive - the Romanian company could be owned by a Cyprus tax resident HoldCo.
Right, it would only make sense if the US equities are part of a much larger portfolio and if the revenues fit into the Romanian micro-company regime requirements.
Not sure how that would help. Perhaps a 501c3 could be used in combination with personal tax residence in a tax free country. The IRS allows 501c3s to pay reasonable salaries to its employees.
Anyone knows if there's a way of getting a lower withholding rate than 10% directly from the U.S.? I know the countries that thanks to a special double tax treaty can get a 10% withholding rate, but is it possible to get 5% or even 0%?
Yeah, and then you run into issues with this new anti-shell thing. Also the setup just gets ridiculously complex.
I know a UHNWI from the US who lives in Thailand tax free. He manages his own family office as a trust. I think it was a combination of two trusts, one of them in... Nevis? Quite complex. But he lives a tax free life as a US citizen in Thailand, as far as I know.
The IRS has published tables with all WHT rates, just google them.
I can't find a country with less than 10% withholding rate on that list, but I've read that you can go down to 5% with different structures, which would cost money.
Regarding Thailand as we all know they have 0% capital gains tax on foreign earned income, but the withholding rate is 15% from the U.S., again, maybe with an expensive trust you can get 0%, maybe...
I don't know the details of his setup, but I know it involves two trusts and I'm sure he doesn't just pay out money to Thailand from the US. It's a lot of money from what I understood, so you can bet it's not a DIY setup, but all done set up by lawyers that don't come cheap, both in the US and Thailand.
Anyway, anything he pays out would only cover his living expenses, which I think are quite moderate in comparison to his wealth... And he probably makes sure to wait 1 year+ before remitting anything to Thailand.
You can also buy accumulating instead of distributing ETFs so the dividends automatically get reinvested and you avoid the tax altogether. For example: "Vanguard FTSE All-World UCITS ETF (USD) Accumulating".
when you liquidate the position and make gains, does the broker withhold tax on the gains?
No, as that's capital gains tax (not withholding tax).
If you're based in UAE there's no capital gains tax so you won't pay that.
Strictly speaking, the withholding tax is capital gains tax as well, just in the other country 😉
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