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  1. Marzio

    Best management location for US LLC

    I asked specifically this question and this is the answer i got from @A1988: Malta sourced income is considered when a service is performed inside Malta and the payment is received from either a maltese resident individual or company. @A1988 who gave you this defintion? It works for him...
  2. Marzio

    Portugal tax resident under NHR + US LLC

    There's a new ruling from PT tax authorities about tax treatment of US LLCs in Portugal.
  3. Marzio

    Slovakia tax resident

    Not sure where did you get that info but dividends are taxed at 10% from 2024 onwards
  4. Marzio

    What kind of business would you launch from a low tax country?

    Start a youtube channel called [yourname]inAndorra where you show Andorra. I don't mean sitting in front of a webcam and talking. I mean making vlogs where you document your environment. You will naturally attract people that want to know more about Andorra and the only people that want to...
  5. Marzio

    Best management location for US LLC

    Yes it would work wonderfully like @JustAnotherNomad just said, i was only hoping to use the excellent SG banking system :p
  6. Marzio

    Best management location for US LLC

    You're right! I supposed that a non resident company wouldn't be taxed in SG.
  7. Marzio

    Best management location for US LLC

    Yes, i completely forgot about SG non resident company! US LLC will still be the leanest vehicle as it doesn't require any local director or secretary. @daniels27 how easy is to to get a SG bank account for a SG non resident company? I assume that since the SG company is not resident...
  8. Marzio

    Seeking Insights and Strategies for Offshore Business

    You are missing that your country of residence will want its slice of the pie because your US LLC company will be tax resident where you live.
  9. Marzio

    Best management location for US LLC

    Since @A1988 has a EU passport he can't stay in GIB without a working presence so the company serves that function primarily.
  10. Marzio

    Best management location for US LLC

    If it's not too much of a hassle could you please ask your lawyer: 1. if a LLP could also be used for the resident non domiciled company strategy 2. what are the requirements for the resident non domiciled company to get a tax residency certificate.
  11. Marzio

    Best management location for US LLC

    I don't know how easy would it be to find a bank for a non resident GIB company. US LLC has way more options when it comes to banking. Then GIB is a no go for you as CFC rules will kick in at 75K passive income.
  12. Marzio

    Best management location for US LLC

    That's the difference right there: 1. Malta is paper residency 2. Gibraltar real residency By going back to sleep in Gibraltar and having his passport scanned he is building his proof just in case anybody will question him. As you surely know this is a spectrum, there are various degrees of...
  13. Marzio

    Best management location for US LLC

    I don't see the payment of dividends from the Maltese company to a Gib holding resulting in a double deduction or a tax deduction without inclusion of some sort. The fact that the Maltese income is not taxed because it's not remitted in Malta it's only about Malta, not about a mismatch between...
  14. Marzio

    Best management location for US LLC

    Gibralter needs a very good reason to declare company tax resident. If the resident non domciled company wouldn't have the tax residency certificate then they could go after him claiming that since it's not tax resident anywhere then it's fair to assume it's tax resident in Gibraltar...
  15. Marzio

    Best management location for US LLC

    The fact that the resident non domiciled company in Malta can access the full imputation system and the treaty network means that is considered a tax resident company so i assume it could get a tax residency certificate from Maltese tax agency. (@A1988 please correct me if i'm wrong). If the...
  16. Marzio

    Best management location for US LLC

    Which flat tax are you referring to?
  17. Marzio

    Best management location for US LLC

    One thing to add is that there are CFC rules in Gibraltar but the provisions do not apply when the accounting profits of the CFC do not exceed 750K and CFC's non trading income does not exceed 75K so if you expect to generate more than 750K in profits then stay in Malta.
  18. Marzio

    Best management location for US LLC

    There's a super new agreement between Spain and UK regarding Gibraltar to solve tax residency issues of natural persons. To answer your question the answer depends on your risk appetite. You could be conservative, commute daily to Marbella, sleep in Gibraltar. You could be reckless and buy a...
  19. Marzio

    Best management location for US LLC

    You are lucky, you don't have to pay as much :) You only need to add a Gibraltar holding company to your actual setup, hire a Maltese director for you resident non domiciled company, move to Gibraltar and get dividends tax free. If you want to do things by the book you would need to invoice...
  20. Marzio

    Best management location for US LLC

    That's interesting. I assume you pay 0% CIT for the resident non domiciled company if income is not remitted to Malta. BTW did you speak with somebody that explained what is considered Malta source income? You then only pay 5K taxes yearly if your personal income kept outside Malta is > 35K...

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