Search results

I thought you were happy in Switzerland?

Yes, so was I. I think you have to apply for the fiscal unit thing. Seems like Gibraltar is quite popular for this. Some also use UK Ltd.'s, but who knows if things will really stay the same in the UK...

I would look at either having the UK LLP/US LLC with the Montenegran company as a partner/member. Then all income would automatically be income of the Montenegran company. Just be aware that if you do have ECI (someone working in the US), then if the US LLC is owned by the company, there will be...

No idea how common that is, but it can get your client in trouble if there is such a law in their country. Just something to keep in mind. You wouldn't have such problems with a different jurisdiction.

I would work with a lawyer/service provider, apparently you have to get your application right to get the 5%. Seems like different service providers prefer different countries for the holding company. I would NOT go with Estonia, they will tax you if you sell your company. But there are more...

Depends on the bank. But I agree, Tello is the best solution if you need a "real" phone number.

Except almost no country would consider this foreign income. But of course, if you live in a less developed country, enforcement is weak and it will work.

Tello or Google Voice.

A transparent single-member US LLC pays tax in the US as if it was the member that had provided the service/sold the goods. So if you or your Montenegran company owns the US LLC, the US will "look through" the US LLC and decide if you/the Montenegran company should pay tax in the US. If you sold...

So you moved to Malta in the end?

I know nothing about Montenegro, but I would expect that using a transparent entity like a UK LLP or US LLC from Montenegro can be quite complicated. From the UK/US side, the income would not be taxed if nothing happens in the UK/US, even if customers are based there (no office there, no people...

Ok. Will it really be so simple to circumvent? Hard to believe the payment processor wouldn't care about the ownership. Also keep in mind Panama is blacklisted by some countries, so invoices from the US LLC may not be deductible for the client (if you do B2B).

Will you have ECI? There is no treaty. You will be paying 30% branch profit tax in the US on any ECI (after paying CIT) that flows to the Panamanian company.

So it's only about documentation?

I don't get it - why have a threshold for transfer pricing rules at all then?

Also seems like the Comoros have a PE concept, but it's probably only relevant if you have local customers (like Thailand)? https://www.orbitax.com/taxhub/coun...21171b89ed/Domestic-PE-of-a-Foreign-Entit-535

Still shows "N" for local income? Seems like they do have a PE concept: https://sgv.ph/c-suite/Tax-issues-arising-from-cross-border-WFH-arrangements

Thread 'List of Territorial Tax Countries with formal and de-facto treatment of foreign income' Jun 26, 2023 In the thread "Where to relocate to not pay capital gains tax and live cheap" it was mentioned that some countries "don't tax foreign income" in the context of owning a business...

Sounds interesting. @JohnnyDoe can you give a few more details?

I think it was @Marzio who mentioned that Malta's transfer pricing rules only kick in from quite high revenue thresholds. Cyprus also seems to have a requirement of at least 1M or so in transfers before transfer pricing rules kick in. Is that correct? If yes, are there other reputable countries...