Search results

Why you claim is not true? look at Estonia Bulgaria DTA Art.4, or Georgia Bulgaria art.4. In case of double residence the country of incorporation prevails. On top of that if in the bulgarian CITA (corporate income tax act) the residency is defined as entities incorporated under bulgaria law...

I am not sure that it would be automatic, particularly for countries having a DTA (see the cases with countries having a DTA) which would define in a relatively narrow way the definition of PE. Honestly to me the PE definition seems extremely vague.

Let's start from this premise: the residence of an entity should be verified according to the local definition of residence (country-specific) and only in case of double residency a treaty could be used to determine the only residency of an entity. Having said that, I noticed that while in many...

Nauru? guys i am not an expert of crypto but you should always check when you operate with intermediaries the country for jurisdiction (forum), the applicable law and if you end up in some strange place where getting a judgement and enforcing it becomes impossible.

having to run away from a country for a simple civil litigation with a landlord is scaring. i believe the UAE may correct such harsh approach to debt, without making discount for fraudsters but avoiding the average joe (the normal guy that has a simple civil issue) to get in trouble. that would...

hi All i see that all of you suggest that micro company is subject to wht 5% on dividends distributed to its mother but according to a recent ordinance and an emendament included it seems that the EU directive should be applicable also to micro-companies (they extended the EU directive...

Are you referring to the risk of being jailed for debt (something indeed that the Romans did - see Matthew 18:30).

i have read that - UAE have no long history of bankruptcy laws, so high risk of getting personal liability for directors/owners - even the risk of a judgement (i.e. a debt) against the person, may generate criminal liability (just based on the debt) if not paid or if the debtor is not solvent -...

this seems more a matter of residence of the company (Place of Effective Management criteria). i believe you are mixing 3 concepts 1) residence of the company (based on internal legislation and on DTAs) 2) presence of permanent establishment (again internal legislation and specific DTA) 3) CFC...

if the salary for managers will still be deductible in the fiscal P&L of the entity and the individual tax will be 0% then theoretically one could pay a big salary basically reducing the CIT. Pls correct me if i am wrong. from the faq " Will an individual's salary income be subject to UAE CT...

hold on. What if somebody gets a HNWI Georgian residency with georgian tax certificate and does the work from outside georgia? (for example UAE). Let's imagine another EU country is challenging your residence, based on Georgia-EU country treaty most probably a tie breaking rule will be a...

what about Georgia? they have 0% WHT on royalties and their DTA is soviet-union USA tax treaty (no LOB) You may have a 1% freelance setup in georgia and get the royalties wht free at 1% or an international company at 5%. In theory also a virtual private zone but that seems to be difficult...

On top of all those valid reasons there is also another one. If you have an LLC and only you as owner everything relies on your personal tax certificate. With a corporate owner in UAE you can get a tax certificate for the entity and another one for you. If they claim your personal residence they...

from Georgia you can receive royalties at 0% WHT from US. There is an old double tax treaty recognized only by US (the Soviet Union CCCP-USA DTA 1973) and give a special exemption on royalties. It's funny that the US consider Belarus, Armenia, etc.. within the same CCCP DTA after 25+ years from...