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It's not for the LOB; it's to avoid triggering high-risk IP substance requirements in IOM. It has nothing to do with the LOB. The LOB issue is still there.

Hi everyone, Thanks for your help. I wanted to share an update. I spoke with a top international tax lawyer based in the UK. He confirmed that the LOB clause is indeed applicable (props to @Marzio ”“ you know your stuff!), but mentioned that, in practice, he hasn't seen it enforced in his 30...

Understood. Let's explore the option of setting up a company in Georgia. Has anyone in the forum had experience with establishing a business there? Can anyone recommend a reputable corporate service provider (CSP) who could also serve as a local director to ensure real substance? Additionally...

Including giving real substance and using the UK company not only for royalties but also ordinary income like charging for management services or set up fees so it's not only royalties ?

Thanks. Personally, I don't think Georgia works as very difficult to bank and wires coming out the US to Georgia might be flagged constantly.

By the way, I was just reading on the ZEC, where every €0.5M of additional revenue after €1.8M requires an extra employee to be hired. So if you make €10M in revenue, 21 employees are needed, up to a limit of 50 employees. So yeah, I don't think it works.

Thank you very much for the information. Unfortunately, I don't think Spain would work for this setup, as the UBO is a Spanish tax resident. Based on insights from the Spanish tax lawyer I consulted and my experience with the tax authorities' approach over the past 10 years, this poses...

Thanks @Marzio. To trigger that rule, my understanding is that it's applicable when the UK company acts merely as an intermediary without substantial economic activity. I plan that the UK company has a lot of economic substance, employees who perform IP management functions (2 of them), real...

Hi @Propeller, Thanks for your quick response. I am not worried about potential lawsuits here, so I didn't consider that when designing it. My understanding of the Bahamas or Cayman is that they won't work since there's WHT both when sending royalties from the US to those entities. Also, when...

Hi, Offshorecorptalk Team! I am working with a business partner on setting up an international group structure, and I will keep 20% of the business while he takes 80%. For the purposes of the structure I have designed, let's say that my business partner runs the most expensive chain of hair...

It seems like I'll definitely need an EU license, then. I'm currently talking to different providers and considering getting a Polish VASP license, but I'm also thinking about how challenging the transition to MiCA CASP might be. Alternatively, I could start preparing the paperwork now and apply...

Thanks a lot. The majority of my clients come from P2P exchange platforms, and while some are recurring, most are new and tend to come and go. My concern is whether simply posting available trading amounts on these platforms would be considered solicitation under MiCA, which could potentially...

Thank you very much, @Martin Everson, for the valuable advice. I wasn't aware of the upcoming MICA CASP applications, and based on what you're telling me, it seems unwise to either apply for or purchase an existing VASP license, especially with the transition to CASP and potential unseen...

Hi everyone, I've been a member of this forum for many years and recently rejoined the Mentor Group --I love OffshoreCorpTalk and hope it continues for many years. Recently, I've been exploring the P2P trading space on platforms like Binance and OKX, and despite its age, it still seems to be a...