bypass 30 percent withholding tax for royalties
- Thread starter FrustratedMan
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Yes if a Ltd, and then you have to pay UK corporate tax on this amount (25/19%).
There are some good reads here
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No any taxes paid, but they did not like the ploitical vibes. (They could just have gone to the country side or taken the expres bus to Armenia over the weekend.
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...
You can either setup a company in Georgia and then pay out the profits to you as active income (if your country does not tax them) or you move to Georgia.
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Post in thread 'Best countries to incorporate for Google Adsense'
Oct 1, 2024Yes, they always exist. You just need to look out for them. I think Cyprus or Georgia should work quite well. There was a couple that was living tax-free on the girl's $3M royalties in Georgia:
No any taxes paid, but they did not like the ploitical vibes. (They could just have gone to the country side or taken the expres bus to Armenia over the weekend.
Thread 'Critique My Lean US - Mauritius Structure (2.1% Effective Tax Rate)'
Sep 20, 2024Good 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
You can either setup a company in Georgia and then pay out the profits to you as active income (if your country does not tax them) or you move to Georgia.
The reason why I asked this, I read somewhere on this forum that if you do a US LLC, they'd still withhold 30 percent as a non resident. Why would a UK LTD as a non resident bypass the withhold tax?
Thanks for the info, but it has to be the UK for a specific reason.daniels27 said:
There are some good reads here
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Post in thread 'Best countries to incorporate for Google Adsense'
Oct 1, 2024
Yes, they always exist. You just need to look out for them. I think Cyprus or Georgia should work quite well. There was a couple that was living tax-free on the girl's $3M royalties in Georgia:
No any taxes paid, but they did not like the ploitical vibes. (They could just have gone to the country side or taken the expres bus to Armenia over the weekend.
[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
You can either setup a company in Georgia and then pay out the profits to you as active income (if your country does not tax them) or you move to Georgia.
Click to expand...
Thanks for the link, I wasn't aware of tax treaties have these kind of limitations. Good to learn!
Georgia.
Another option would be to set up a US corporation and then get the money out from the US corporation in some other way.
Another option would be to set up a US corporation and then get the money out from the US corporation in some other way.
If I understood it correctly, withholding tax depends upon where the UBO is resident and not the company? "The provisions of paragraph 1 of this Article shall not apply if thebeneficial owner of the royalties, being a resident of a Contracting State, carries onbusiness in the other Contracting State, in which the royalties arise, through apermanent establishment situated therein, and the royalties are attributable to suchpermanent establishment. In such case, the provisions of Article 7 (Business Profits)of this Convention shall apply"
What is the withholding tax for it in Georgia? And HNWI tax residency works for that option?
The UK-US tax treaty (like most modern tax treaties) have LoB clauses, so it matters where the UBO is resident.
Not with Georgia, because these are old Soviet Union tax treaties that didn't have LoB clauses yet.
Not with Georgia, because these are old Soviet Union tax treaties that didn't have LoB clauses yet.
No. You just need a company there and then pay out the profits to you. Beware that there are profit taxes. If you move there as per the linked articles, you can get the royalties personally tax-free.
Georgia is the way to go. I wrote up this for the other linked post: https://www.offshorecorptalk.com/th...ture-2-1-effective-tax-rate.46119/post-341054
US tax treaties are structured in a way that to access the benefits of the treaty UBO has the be tax resident of the country used to claim the treaty. If a UK entity (either a company or natural person) claims the benefits of the treaty it has to pay UK taxes.
There's no way to avoid that and i assure you i've read every word of those treaties, i've read technical analysis looking for a loophole, there is none that can be exploited.
Georgia is surely an option but banking will be problematic, especially when you receive USD.
I wouldn't keep the banks in Georgia; instead, I'd use a private bank””definitely not Wise either
Do you mean that if the UK company doesn't claim treaty benefits then it doesn't have to pay UK corporate tax on the income? Or would have to pay both 30% royalties and 25% UK tax?
If UK company wouldn't be able to access the benefits of the treaty would have to pay 30% US WHT on royalties and obtain a credit for the taxes paid overseas but obiously up to the UK CIT so max 25% or 19% depending in which tax bracket would fall the UK company.
This happens with countries without a US tax treaty. For example UAE where you will pay 30% US WHT on royalties plus 9% UAE CIT, not funny.
This happens with countries without a US tax treaty. For example UAE where you will pay 30% US WHT on royalties plus 9% UAE CIT, not funny.
If you don't have access to treaty benefits, you have the same situation as if there was no treaty. So there can be double taxation.
Most countries give some relief (tax credit) for tax paid overseas, even if there is no treaty.
Most countries give some relief (tax credit) for tax paid overseas, even if there is no treaty.
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