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Hi! Apple is not withholding, and neither is Google as far as I have analysed the payouts. If you want to do the same, watch out because Apple looks like they pay you at the end of the month or in the first days of the following, but they actually have an average delay of 33 days. Apple fiscal...

Which would be different from capital gains, right? Also, Cyprus IP Box has only 2.5% corporate tax, and as a Cyprus resident non-dom, you pay 2.5% on dividends, I think?

Yes, the UBO of the company can be from anywhere else. Their identity must be disclosed when submitting tax information for the US, and the nominee payment person must show that they have the necessary power of attorney to submit that info on behalf of the UBO.

I have subscriptions only as in-app purchases, no ads or purchase of items, and judging from the greenlights I got, they are not subject. The way their W8BEN adapts to your situation is impressive and I think leaves little room for doubt. The person owning the Google Payments account used for...

I have consulted with both a US tax specialist and one in my local jurisdiction and there is no problem from the US. This said, Marzio had previously argued that according to Article 4 of the DTT that the free lunch you get fromt the US does not apply if you are only liable to tax sourced in...

How can you be the one asking me that? You're the master of it all! :p Doesn't it all come down to your interpretation of that passage of the US-[country of choice] tax treaty? Regarding the link: the guy doesn't specify whether he is a person or an organization on Google Play/App Store. Also...

Hello! I wouldn't want to overestimate my experience, but I thought about giving something back to this fantastic community. I have at last managed to publish a mobile app for iOS and Android through App Store and Google Play. The app has in-app purchases, which have already been paying...

Bumping this if it's ok?

Hello! as per the title. I remember creating a Wise account short after creating my SM US LLC, because Wise didn't even care about you having an EIN. I keep hearing funnies about them and I now have an EIN, so I wonder whether I should go with Mercury, or anybody else. I haven't started...

Precisely, yes, UK TIN. I'm unlikely to get any revenue or in fact any financial activity before the end of the LLC's first year (which ends at the end of January). So I should have time to rectify after that deadline.

Hats off to you Marzio, as always. In the meantime, my more immediate question (the one of the topic) got an answer. It's too late for my timeframes to go for an ITIN. I'll have to claim 0% withholding for now and then change. Does anyone see any problem with that? Many thanks as usual, to anyone.

All to be seen. I guess the important requirements are max 20% taxation for eveything and basic anonimity (i.e. from the public eye, not authorities) for the App venture. But time is running out, I think I might start with 0% US withdrawal (because that doesn't require me to get a US ITIN to put...

Cyprus or Portugal. Essentially, somewhere in Europe that doesn't require me to stay there too much (I won't be staying in other country for more than 5 months a year anyway) and that won't ask for more than 20% tax between corporate and personal tax.

Hello, Setup: I'm a non-dom tax resident in the UK who will soonish (Q1 2023?) start to sell an app product on App Store and Google Play using a single member Wyoming LLC. I thought I could avoid US tax simply because I am a Non-Resident Alien to the US and the SM LLC is a disregarded entity. I...

My app won't have adverts nor income coming from them... Does what you say still apply?

Back to the W8BEN, @marzio how can I differentiate the fact that I should have 0% witholding on the Apple revenue but probably something on the Android revenue? Do I submit a form for each source of income?

I still have one benefit: anonymity to the godd@mn public eye of any average joe with an internet connection. Which I wouldn't have if I incorporated in the UK directly.

Ok, the bigger screenshot finally makes sense of what you are saying. I see what you mean but I believe it can all go down the drain because you can wilfully elect to bring in all of your outside-of-UK income to the UK and pay tax for it? I am based in the UK. My app business will be run from...

"Now tell me, are you as a non-dom liable to tax in that State?" No, but I am liable of tax for that income in the UK. Look I appreciate the heads up, but I'll have to take it to a tax advisor in the UK. If you are right, what's the point of so many US non-resident aliens going for US LLCs?

I can become dom if needed? I am a fully regular tax resident of the UK, otherwise... It's the first that I hear that the US care about the UK tax resident being non-dom or dom. In fact, two tax advisors confirmed my set up... And, to be honest, I don't see the dom vs non-dom specification...