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What matters is where the work is carried out. For an app business the selling is done outside of Malta by the platforms and if you think about it the 30% that Apple deducts from appstore sales are exactly sales commissions. App development is done in UAE. Nothing is actually done in Malta...

Please elaborate as to way subscriptions wouldn't qualify. By foreign asset what do you mean?

Since you are not the one engaged in sales use a resident not domiciled company in Malta owned directly by you. The resident non domicile company in Malta will be tax free as long as: 1. no work is performed in Malta 2. no income is remitted in Malta 3. is managed by a director in Malta You...

I honestly never used them so i can't say anything from direct experience.

Don't bring beer and sausages!

Make base erosion great again!

What do you mean?

Georgian LLC works the same way, they are taxed only upon distribution at 15%. If you are into software dev look into international company status, if what you do is a permitted activity then you'll be paying 5% total tax which is not 1% but you are doing things by the book and there's no...

These days it's hard to open a UK bank account for a UK LTD, i imagine how easy would be to open for a Georgian LLC unless you show up with a lot of £££££££

Yes, that's correct. When i said "just pay 19%" i assumed that UK company would qualify for treaty benefits so the US WHT on royalties would be zero. If the UK company wouldn't qualify for treaty benefits what i said before stands. When i factored in the 5% Georgian WHT on dividends for some...

There are none. Sure, but what's the point? You will have to pay Georgian CIT on those royalties upon dividend distribution which right now is 15% plus 5% Georgian WHT on dividends. Just pay 19% in UK.

The only thing i'd like to add is that RIGHT NOW the US-USSR treaty is unidirectional so US still obeys to the old USSR treaty (which includes Georgia). The problem is that Georgia doen't recognize that treaty as valid from its part since the treaty is with USSR and not with Georgia so when...

If UK company wouldn't be able to access the benefits of the treaty would have to pay 30% US WHT on royalties and obtain a credit for the taxes paid overseas but obiously up to the UK CIT so max 25% or 19% depending in which tax bracket would fall the UK company. This happens with countries...

Where would you bank?

I'm not aware of any Georgian bank or Kyrgy bank in any tier-1 jurisdiction. Is there any?

I guess it's a sort of IP Box where you are granted a relief on the statutory CIT rate if you have some kind of R&D expenses to develop your IP. Be aware that there's no Stripe in Andorra. Your only option would be to use Braintree (a PayPal company) the fee is 1.9% +0.30€ which isn't bad at...

US tax treaties are structured in a way that to access the benefits of the treaty UBO has the be tax resident of the country used to claim the treaty. If a UK entity (either a company or natural person) claims the benefits of the treaty it has to pay UK taxes. There's no way to avoid that and i...

Those options on paper are all good, the main problem you'll have will be with banks. I don't have any direct experience with receiving USD in Kyrgyzstan but i know from direct experience and from various people in the forum sharing their experience with Georgian banks that you'll be boggled...

Impossible bcecause of art23 in the UK-US double tax treaty. Which is?

Lets wait for a reply from @A1988