Best countries to incorporate for Google Adsense

[yngmind]

UK has no tax on royalties when paid from the US - United States - Corporate - Withholding taxes

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[daniels27]

yngmind said:
UK has no tax on royalties when paid from the US - United States - Corporate - Withholding taxes
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Yes, Denmark too. But you may end up paying more there?

 

[yngmind]

I just had a call with a lawyer, and here's the summary.

First, we need to check if there's a DTT with the US for the country we're considering.

Then, we have to look at the royalty tax rate in that country. You can check the details here: United States - Corporate - Withholding taxes. It should ideally be 0%.

Next, it's important to choose the right country.

A UK LLP could work well, and Kyrgyzstan is an option too, but you'd have to go there in person to set up banking, and the reliability of the banking system is something to think about.

One key point my lawyer mentioned is the need to create substance in the country where the company is formed. This ensures no one accuses you of using the company purely for avoiding U.S. royalty taxes.

To do this, renting an office, hiring a local director, and paying them a salary are good steps to reduce any risks.

This approach makes it more solid and compliant.

The next problem is tax residency, probably I would have to sign W8BEN-E, and UK company should be a tax resident of the UK by default.

Last edited: Oct 3, 2024
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[daniels27]

yngmind said:
First, we need to check if there's a DTT with the US for the country we're considering.

Then, we have to look at the royalty tax rate in that country. You can check the details here: United States - Corporate - Withholding taxes. It should ideally be 0%.
Click to expand...

Yes, I always used this page. You not? UK LLP works but only if you spend out all money on fiverr to the final destination. If you setup as UK LLP tax transparent, I think the main problem is that if your company is not paying taxes there because not tax resident in UK, you technically do not fulfill the DTA requirements and are very likely subject to troubles. I think with Google more or less checking, it may slip through for a while, but certainly is not a stable situation.

The question is how you want to get the money? Like the fiverr guys that they need to pay personal tax elsewhere? Or you want to get it as dividends from a company (more flexible as more countries have no taxes on dividends than on personal income)?

Kyrgyzstan and Armenia may work, just need to make sure to fulfil the requirements of the free zones. Do you think we can claim that the income is from software development? I mean like programming websites which then make ad income?

 

[Marzio]

yngmind said:
A UK LLP could work well
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A UK LLP would not work because it's not tax resident in UK so you can't provide TIN to claim 0% WHT on US royalties.

Also you should familiarize yourself with the IRS limitation on benefits table.

You'll quickly discover that there are only a handful of places worldwide with 0% WHT on US royalties + no LOB clause in the treaty.

 

[yngmind]

The easiest route is to be an entrepreneur with micro business status in Georgia, but it's up to 165k$

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[daniels27]

Marzio said:
A UK LLP would not work because it's not tax resident in UK so you can't provide TIN to claim 0% WHT on US royalties.
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Yes, that's what I was trying to say and thought.

Marzio said:
Also you should familiarize yourself with the IRS limitation on benefits table.

You'll quickly discover that there are only a handful of places worldwide with 0% WHT on US royalties + no LOB clause in the treaty.
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All CIS. But even if there are limits, you could actually meet them if the business is proper.

Ok, so back to the question. Can we do free zone somehow?

 

[daniels27]

yngmind said:
The easiest route is to be an entrepreneur with micro business status in Georgia, but it's up to 165k$
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Yes, but you need to live there. I like it but some did not.

 

[Marzio]

yngmind said:
The easiest route is to be an entrepreneur with micro business status in Georgia, but it's up to 165k$
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Or go with the Georgian HNWI route.

 

[daniels27]

Marzio said:
Or go with the Georgian HNWI route.
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I think the other guy did $3M per year tax free in Georgia. I think it is not too bad. Life is good there.

 

[Marzio]

daniels27 said:
I think the other guy did $3M per year tax free in Georgia.
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Who?

 

[yngmind]

Marzio said:
Or go with the Georgian HNWI route.
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How it's gonna help you though?

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[daniels27]

Marzio said:
Who?
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Leo Vanguard
[IMG alt="Leo Vanguard"]http://localhost/data/avatars/s/36/36063.jpg?1731302862[/IMG]

Thread 'Critique My Lean US - Mauritius Structure (2.1% Effective Tax Rate)'​

Sep 20, 2024
Good day Gentleman.

After wrestling with a UAE freezone/US LLC setup that turned into a compliance and AML audit nightmare (9% UAE tax, anyone?), and after spending some time in Georgia before realizing the political vibes weren't for us (Hello Putin...), we've finally think we have found our sweet spot in Mauritius.

Why Mauritius?

Two words: tax perks and lifestyle.

It's by far the best run island I've ever been to - seems to have the chilled beach life when you want it, futuristic infrastructure in the built up areas as well as some high-end, modern villas with epic...

• Leo Vanguard
• Replies: 48
• Forum: Offshore Company

• 

 

[daniels27]

yngmind said:
How it's gonna help you though?
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You only pay taxes on Georgian sourced income and all royalties are exempt without the limit you quoted above.

 

[yngmind]

Anyway KG seems like a solid option, especially with the

https://htp.kg/
I already see some YouTubers are residents there.

Do you have to pay in the tax on the distributed dividends ?

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[yngmind]

What would you do about this withholding tax on dividends in KG? How it's gonna work?

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[daniels27]

yngmind said:
What would you do about this withholding tax on dividends in KG? How it's gonna work?
Click to expand...

Yes, like this:
https://taxsummaries.pwc.com/kyrgyzstan/corporate/withholding-taxes@Marzio said it very well:

Marzio said:
First thing first you should have a UAE holding company.

The only countries that have 0% WHT on dividends with UAE are:
- Kyrgyzstan 10% CIT
- Tajikistan 18% CIT
- Turkmenistan 8% CIT
Click to expand...

But if you do HWNI, you get the royalties personally and they are exempt.


With Armenia, there are more options:

daniels27 said:
I think with this amount even an Armenia free zone could be possible. You can then transfer out the dividends through Singapore, maybe even through a private fund.
Click to expand...

https://taxsummaries.pwc.com/armenia/corporate/withholding-taxes

 

[DeepDrilling]

yngmind said:
Getting a PIN seems like an easy tasks, I'm just curious about the small details, like can you forward it, or exactly you must receive the package and sign it with the delivery guy, there are packages like that with the ups/dhl.
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Who else should respond to that if not the provider you've used to establish your company? This thread doesn't make any sense to me. And if your service provider can't receive a package or letter for you, then you can find another one who will.

 

[daniels27]

DeepDrilling said:
Who else should respond to that if not the provider you've used to establish your company? This thread doesn't make any sense to me. And if your service provider can't receive a package or letter for you, then you can find another one who will.
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The question was just about hour they deliver the code. It is like Amazon. They write that they will send for a confirmation code by DHL where you need to be personally present and sign an oath while holding 8 forms of identification and a photo of their mother, while they actually and an email it a simple letter.

It was a legitimate question although entirely off-topic.

Let's stick to the topic. Who else has a lot of royalty that he needs to get without to much taken off?

 

[yngmind]

So, here's how it works with Google:

You register a new AdSense account, receive a PIN code, and then confirm it on the AdSense website. After that, you submit the W-8BEN form if you applied as an individual, or the W-8BEN-E form if you applied as an entity.

From that point, Google stops withholding any taxes, and it's your responsibility to handle taxes on royalties.

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