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How about local services directly in Romania? Anyone has experience with them? There has to be way more options and competition than online.

Makes sense. I read they copied their judicial system from France.

Thanks but an UK LTD costs 20 GBP, an US LLC costs 150 USD, 500 EUR for a Romanian SRL is clearly a ripoff

Anyone knows about any reasonably priced Romanian incorporation services? I've contacted a few that I found Googling but they want about 500 EUR for a SRL formation. Pretty expensive compared to just about any other jurisdiction.

I meant by terminate that the tax obligation won't “flow” to me personally anymore, it will end at the LTD. I need an LLC because I want access to US brokers - they offer better tools, lower costs and no EU restrictions. So now the question was what to do about the taxation on my end...

f**k I forgot about the CFC rules. Holy s**t this tax planning and lawyering is frustrating. Romania still the best though. In the EU CFC rules apply only if the company has no substance in the country of incorporation. It's easy to create one in Romania.

Does a branch office create a permanent establishment? According to the usual DTT tax treaties that'd move the tax obligation to that country from the country of registration, proportionally to the profit attributed to that establishment. So if an LTD creates a branch office in Romania, is...

got it Seems like the UK LTD + US LLC combination is really useless, because the LLC needs to be managed from somewhere and that country will claim its profit for taxation, whether it's the UK or some other country. So it's again Romania. In fact only Romanian SRL + sole proprietorship. The...

What are the tax implications if an UK LTD is holding an US LLC, the LLC is non-ETBUS, and both are managed from a) 3rd country that doesn't have a tax treaty with the US and the UK b) 3rd country that doesn't have a tax treaty with the US but has with the UK In the case a) will the LLC be...

hmm the UK considers dividends received from overseas subsidiaries to be non taxable (mostly, under certain conditions), and at the same time considers LLCs opaque and draws as dividends ... So if the LTD is managed from the UK, and the LLC is not, and all the LLC's profits are paid to the LTD...

... nope, if an LLC is managed from the UK it'll be seen by the HMRC as having a tax residency in the UK therefore liable for the UK corporate tax on its profits. Unless you find a place to manage it from that doesn't appropriate the LLC. Having an UK LTD parent then would be beneficial as a...

Not even a virtual card? Mercury offered me a virtual card or a real card.

Alright, I'll keep it then. And open Wise for international transfers.

I'm not going to keep much money in the account, just to cover expenses, the rest will go to a brokerage account.

In fact I'm planning to drop them for Wise because I'll be sending money abroad, and I'd like the transfers to be exact in the local currency.

Well I was telling the truth. My clients are really exclusively in the US. Just saying that could be the reason for rejection.

I think the issue is that your clients need to be US based. I told them my clients are in the US exclusively, I have no social media presence, no website, got approved without a problem.

Ok so to recap: A Delaware LLC subsidiary, an UK LTD parent, owned and managed by a non-resident of the UK from the UK. LLC: no tax in the US (non-ETBUS, pass-through) LTD: no tax on LLCs profits, only on draws which are treated as dividends. The LLC is considered a CFC in the UK but fully...

How exactly will things change? Thanks to the CFC exemptions and the opaque classification of LLCs it seems to be only beneficial for the LTD to have a substance in the UK.

Also it's interesting that the UK has multiple full entity exemptions from its CFC rules, many of which could apply to an LLC subsidiary if it's managed from the UK. https://www.menzies.co.uk/controlled-foreign-company-tax-exemptions/ Therefore it looks like by managing the structure from the...