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I already checked and CFC rules do not apply. Hello, royalties should be paid from the company to me regardless if Apple or Google treats them differently. Here the royalties are intended of the economic utilization of my intellectual property (the app) by a company with which I have signed a...

How the Lux company can be controlled from my home country if I am not even the director of it? I cannot receive the income personally since it is a two-men business so we need some sort of company to collect all the profit and then distribute, otherwise it would have been much easier to...

I think he's referring to this: Tax Benefits (also in the website says it is not doable anymore in 2022 unfortunately) Problem is that I ready it will be available only until 2027 and also I do not know if with the NHR regime this can be considered as Portuguese income if you then after paying...

The Lux company will pay me for the use of my intellectual property work (my app) with a written agreement between me and the company (this should be how all royalties agreement works). I can even register the app as an intellectual property if there needs to be this kind of documentation. The...

I have had the app for several years, even before the company was incorporated so this proof can be obtained easily. Clearly, royalties payments are deducted from company taxable income since me and my business partner are the owners of the app.

Hello, I would like to know if I can achieve a 0 % tax setup with the following business. I have a mobile app business and I read that foreign royalties according to Portugal NHR are tax-free. If I create a company in Luxemburg, administrated by a local director and receive all the money from...

I think it count as royalties since if you do not provide a treaty to use they withhold the 30% tax. At this point, if we use a C-corp and have to pay the corporate tax I do not see how it can be useful. The only way is to create another business that takes out all the revenue of the C-corp as...

Thank you for your suggestions. The problem is if the US C-Corp is managed and directed outside the US are we sure it can be seen as a US opaque entity even if it is a C-corp? From what I understood the place of management and controls determine where the company resides. In your particular...

If you use a pass-through LLC and are not a US Person I do not understand how they could tax you. I may have found another solution by moving to Portugal with the NHR program. I read that foreign royalties are not taxed. Since Adsense (as of June 2021) now count the money they pay you as...

If you want to risk wouldn't be better using a US LLC with no public records and sign a W8BEN with your home country documents instead of a UK LLP ?

In the case of software at this point the best one is Cyprus using IP Box Regime to obtain 2.5% CIT Apparently there is no way to obtain 0 % tax rate ,am I correct? We can leverage a low taxation using some eastern europe countries but cannot achieve 0 % from what I understood from the...

Life quality is good (food, people and summer is very enjoyable here), but during winter like now especially in the north is very cold. Also here the bureaucracy and taxes are too high, it is nearly impossible to run a tech business here. Most of the time is spent dealing with government filings...

27 % and also your income will go to IRPEF which is a progressive tax with brackets, so if you make very large sums it can be a problem.

I am from Italy, please guys stay away from here. Here it is a tax hell and even by using this tax deduction you are entitled to pay social insure contribution to INPS. I want to move away from Italy as soon a possible! haha

Yeah unfortunately :( At this point I do not understand why you created an LLP where there is public register that shows that you residence is in UAE, better use an US LLC and sign a W8BEN to Google using your home country documents, at least there is no public evidence available proving your...

@WIE7 What about an Estonian company with UAE shareholders and directors. Wouldn't the Estonian company be recognized as a UAE company by Estonian tax man since it is administrated from UAE (but still leverage tax treaty between Estonia and UAE) but considered as an opaque company from the US...

Hello, I may be interested in buying some darks, if you have any please PM me (passport or government-issue id)

US LLC being a Thailand resident, since Thailand has a tax-treaty with US and it is a territorial tax system total tax would be 0 %

Can someone confirm this? If the LLC is owned by an Estonian company can we leverage the tax treaty between Estonia and USA while submitting the W8BEN-E ? The problem will be that then the money goes from LLC to the Estonian company and from there you cannot take it out as dividends since they...

Thank you! Are there other solutions apart from Georgia?