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Seems salaries are only deductible if paid to citizens of Georgia? In any case I would opt for the Virtual IT Zone person. Problem is that even if you get a positive ruling in advance I am a little bit scared about this since seems that lot of audits have happened to those companies and the...

Thank you for your insights on Georgia @oldtimer2 ! Regarding the Virtual IT Zone Person what if the software is already produced but the company continues to improve it, adding more features, updates etc and also at the same time producing more softwares? Is the 5% WTH tax on dividends...

Hello, if your service is done without having a dependant agent or facility in US and without requiring your physical presence it will not be subject to any US tax since it is considered as personal services or labour outside the USA. Having USA clients does not necessary trigger ECI...

Yeah, and maybe add some minor features to the app. We also have a contractor agency that handles our ads mediation stack for example by managing waterfall prices for the ads we display, and adding new ad networks and ad instances. We have also recently onboarded another company to handle ASO...

The problem is that every software is unique so it is difficult to do this comparison for my personal specific case, also because since in our case the software produces passive income even a 5% profit for the company (and 95% royalties for us) should be a good deal (company side) because this...

If I am able to set up the royalty company no need to have a UK LLP I could just sign two personal royalty contracts, one for me and one for my business partner and we are good to go. That is what I am already doing for two years with my current setup, problem is that we optimized a little bit...

Hello, I have made the payments as per the instructions using the link.

Best option so far, don't know if it is feasible though LOL Yes, but depending on the jurisdiction the UK LLP can be subject to taxes, for example in Portugal and unfortunately does not solve the WTH tax problem :/ Yeah, my impression is that this NHR system will cease operation and more crack...

Yes, the problem is that you need a company that receives the payments that then directly pays to you this passive income since unfortunately I am not alone but with a business partner so I cannot receive Google Payments directly. I recall I found an article about US LLC under Portugal NHR...

Unfortunately Google applies WTH regardless of you being client of Google US or Google Ireland. For example even if you have an European company and are being paid by Google Ireland, Google asks for W8BEN-E and applying for a tax treaty form otherwise it applies the WTH tax (even this does not...

Thank you for the very valuable insights. I was also considering UAE for my personal residency due to the attracting economic environment, because let's face it, Apart from 0% tax on paper you also need to be certain that the tax man of that country is not that aggressive, like for example it...

Thanks to clarify this @marzio, that is probably also why the CPAs I talked to suggest to build some substance and the type of substance probably depends a lot on the nature of the business and the day-to-day operations it requires I guess. In my case those are luckily not that much that is why...

The CPAs I talked to where referring in building some substance in the country where the company is in order to avoid it being classified as a shell company like you mentioned, but no need to have somethings crazy, even a part-time employee and a local director are sufficient from what they...

I talked with several CPAs and if done in the proper way this is completely legal and doable, the important thing is doing it in the correct way. Clearly the company needs to have some substance like a local director or employee. Since the software is yours you can license it two whom you want...

This is not an issue if you personally own a software and the Georgian company is using it under a license agreement you have signed with them, this is done also by lots of big groups that shift profits using royalties on trademarks, clearly there need to be some substance in the Georgian company.

Probably the IRS has discovered and gone after this because there was a US individual involved, otherwise they wouldn't have bothered that much, but I might be wrong. Georgia, which has no LOB might work in this scenario. Do you know any other countries which have a tax treaty with US and no LOB?

Guilty tax is for US resident or citizen. Yeah I agree with you, but you can stay in UAE sometime and then spend most of other time in Thailand, Malaysia or other countries in Europe without staying too much to avoid triggering any tax liabilities there. Then a company in Georgia that has no...

I am not a US citizen so no need to move to Puerto Rico, there are lot of other possibilities abroad. To avoid the US WTH tax you have to create a company in a country which does not have any WTH on royalties with US like the ones mentioned above and then move those profits to yourself while...

Yes, the trick was finding a country where the withholding tax regarding royalties from USA is 0% like Luxembourg, Ireland, Switzerland, Cyprus and others. Problem is that I do not trust a lot the NHR system because Portugal is changing the rules frequently, for example with Crypto, and if they...

Hello, in theory no since CRS reports account balance and not the transfers made. Also the intermediary bank is only used to make the transfer and since you do not have any accounts with that institution it does not have any obligation to report you under CRS.