Search results

I guess HK is a special case because Pwc writes that they don't really have a concept of "tax residency" - they only look at "source of income", which is similar, but not quite the same thing. Anyway, tax treaties should probably fix this. And in my example, I was thinking of companies that have...

Which country's hybris mismatch rules would apply? And how would it be a hybrid mismatch? Aren't hybrid mismatch rules about where country A sees something in a certain way (for example, a tax-deductible expense), but country B sees it as something different (for example, a post-tax dividend)...

What if the remote team members are hired as contractors (since you probably can't hire employees without registering a branch or subsidiary)? But what if it's the owner's base? Wouldn't that be a "place of management"? And then if no other PE can be proven, profits would be attributed to that...

It's very simple: 1. Many advisors are simply uneducated. Especially when they are only simple accountants and not tax lawyers specializing in international taxation. So there's a good chance you were simply misinformed. 2. Some countries have such rules in theory, but don't have the resources...

Old topic, I know. But there is no such thing. The US LLC is disregarded for tax purposes, so it is treated as if it doesn't exist - it's as if you had received the income under your own name. Hence your question becomes "If I live in a tax-free place and I receive income from the US, will the...

I think this is mostly a question for @Don : If you register a company in a country that only considers companies tax resident if they have their PoEM in that country (for example: Gibraltar, Singapore, Hong Kong, possibly others), but then you manage this company from a country without PoEM...

Thread 'I tried opening a US business account in 18 EMIs, here's the result' Mar 9, 2024 I have a US LLC, am non-resident in the US, and signed up to 18 different EMIs. This is the result after a week: 3S Money - Asked for $20 to process my application + it charges $100 a month for having the...

He wrote it's an e-commerce business. Some people say there is increased risk of being ETBUS with Amazon FBA etc. Done some more googling, it seems like something like that existed 20+ years ago: https://www.gibraltaroffshore.com/exempt-company/ It seems like there is now a non-resident...

Be aware of ECI. The BPT could be a problem. Are you sure? Don't they only exempt foreign income from tax?

Keep the UK Ltd. as a holding company for the new Malta company, then you can get the 5% tax. You need a holding anyway.

What do you mean?

What do you mean?

Come on, you know that he can't escape Italian tax by setting up a US LLC with a "PE" (lol) in Estonia. That would be like claiming he travels to Estonia every day to work from his office there. Even if he started completely fresh now, this wouldn't work.

bulls**t. Same goes for @Don 's suggestion above. Not only has the crime already been commited, adding another shell company OP wouldn't make this more legal. Even though the US or Estonia might not tax this, Italy would. And hiding the new company from the Italian tax man would be another crime.

If you run an offshore business from the UAE, in theory, the UAE can tax that company just like any other high-tax country does. But at least for now, I don't think this has happened in practice. It's quite unlikely to happen anytime soon. If you receive a salary from a non-UAE business and you...

By not triggering corporate income tax.

That's possible, as salary income isn't taxed. In theory, however, they could charge CIT on the PE, or even deem the whole company tax resident in the UAE. Just like if you were living in e.g. Denmark and you were running a UAE company from there, which just pays you a "salary". In practice...

It all comes down to where you/your family live and where the assets are located. If you live in an EU country, there's a good chance they won't recognize your offshore structure and treat any assets as owned under your own name.

Sure, why not? If you show them there is an office in Germany, why wouldn't they?

https://www.sovereigngroup.com/news...nt-nhrs-now-face-large-tax-bills-in-portugal/