I am a tax resident in Georgia and want to set up an offshore company in Hong Kong for a marketing services business. I plan to appoint a nominee director. Is this possible, or in practice, will they say that the company lacks substance in Hong Kong and require me to pay taxes in Georgia?
Tax residence in Georgia and have HK offshore company
- Thread starter Lolloeoicrypto
- Start date
- Status
Introduced in 2021. However , it seems that entity is not treated as CFC if:
* Registered in juriadiction with >15% CIT
* Not holding
* Annual revenue < 1M GEL
In theorty, it is possible that they will deny the offshore exemption and ask you to pay taxes in Hong Kong if you do not pay taxes in Georgia, although there are not many reports where it happened. We discussed this a couple of times.
There is no issue with you creating a Hong Kong Company and you can use a Nominee Director in HK. Nominee Shareholder is also possible, but you could use a Trust or Foundation to help avoid any CFC situation.
It is possible under CFC rules that Georgia could claim that taxes are payable where their is no substance in HK, but if you need to put in place substance this is also possible. If you remain below the levels where CFC applies then this will not be an issue anyway.
Toggle signature
It is possible under CFC rules that Georgia could claim that taxes are payable where their is no substance in HK, but if you need to put in place substance this is also possible. If you remain below the levels where CFC applies then this will not be an issue anyway.
Toggle signature
Not sure if I understand correctly. But if you have substance in Hong Kong, it will most likely be taxable there at 8.25% for the base and then 16.5% in the remainder.
- Status