Article 21, Limitation on Benefits.
At least 50% of the company have to be owned by Bulgarian tax residents, otherwise you can't get the lower rate. Even if you have 100 employees in Bulgaria.
It has been discussed here many times before.
And then what? Depending on where you live, they won't be recognized.
As far as I know, DIFC has their own private courts that follow UK law, but how independent can they really be?
You're very welcome.
US LLCs are super simple to set up. You can use a service like Northwest Registered Agent or IncFile, it's about $150 or so.
If nothing happens in the US, the annual paperwork is usually minimal, so you can either do it yourself or pay someone $300-500 a year to handle it...
Yes, absolutely. Such matters are completely separate.
I think you are confusing permanent residency with just "residency", but you can absolutely become tax resident on a tourist visa, for example, yes.
And there have been cases where the tax authorities were demanding tax for unlicensed or...
If you have local expenses, yes. Most service-based businesses without local customers also won't have a lot of local expenses, and VAT comes with additional work and costs (accounting, declarations).
So you'd need quite a bit of local expenses for the VAT stuff to be worth it.
No. Unless you explicitly want your company to pay tax in the US as a corporation, but why would you want that?
You pay zero tax in the US if the LLC is tax-transparent.
See my detailed explanation here:
J
Post in thread 'Wyoming LLC vs UK LLP'
Mar 3, 2025
A transparent single-member US LLC...
There's a minor distinction here:
Most high-tax countries tax the worldwide income of tax-resident companies and they have both PoEM rules (place of effective management) and PE (permanent establishment) rules.
If a company has its effective place of management in their country, the company is...
Permanent establishment is about where work is done.
If you register your company in the Bahamas, but you really live in Spain and the company has no other employees than you and you basically do everything from your apartment in Spain, then the company is taxed like a local Spanish company. It...
Does that product count for HSBC Gold? I just recall seeing a larger table with all kinds of fees. Maybe they have different fees for different markets? Interestingly, if you are an HSBC UAE client, it seems like they will give you an account with IBKR UK...? Would that count then...?
You should ask HSBC, but as far as I know, yes. But then again, their fees are high. If I remember correctly, the charge a fee based on AUM, and then their fees for trading are high as well.
Thanks. Yes, it definitely seems quite complex.
But it also seems like something that might work well for someone who wouldn't mind actually living in the UAE. Substance shouldn't be an issue, you would need substance anyway for proper transfer pricing.
But how can you get certainty if your...