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Hi thanks for your reply, I'm Interested to know how that would work, can you elaborate a little?

No need to ask if he already explained it. Before I had a UK Vat number, Amazon marketing in the US were adding VAT to my advertising spend.

Someone else has said on here that it will be taxed at 15%, if it is not going to be taxed in Georgia, where will it be taxed then? Is not the LLC liable to be taxed in Georgia due to the owner being located in Georgia, and this is the purpose of a disregarded entity? If that is the sacrifice...

I require a holistic approach that incorporates all elements. If I move to Georgia without a company, will I have to pay VAT on ad spend in the US and UK? Yes currently, UK ad spend does add 20% VAT. Only if I do not use an LLC, otherwise it is taxed at 15%. So, Georgia solves things for...

I guess I need this: LLC (removes VAT from ad spend in US and Uk) > beneficial owner in country with 0% withholding tax agreement with USA, that country does not levy corporation tax on foreign income, and then a very low income or dividend tax to distribute the funds to myself. Any...

At the moment yes I pay VAT on ad spend in the UK (but receive royalties net of VAT), along with corporation tax, income tax etc... (no VAT in the US due to having a UK VAT number and no WHT under the double tax treaty). I think having a US LLC will remove VAT on UK ads as well (provided I live...

That's what I thought. I need the LLC to remove VAT liability from ads and withholding tax from revenue. Just need a location that will then not tax the royalties after this, however, it appears the beneficial owner's location would determine the withholding tax, so it has to be a location...

Sounds good! I thought not taxing foreign income was only for individuals in Georgia and companies would be taxed anyway. Yes income is derived from historic work. If I wish to add to this I believe I should be able to work outside of Georgia half a year if required.

Fair enough. I found that advertising only amplified my sales. I'm in the UK with a VAT number so I do not pay VAT in the USA, however a move to Romania and a switch of structure would mean VAT has to be paid and that is a fat 20% on spend. It looks like what has been suggested is the best...

Another question in regards to this, would the LLC not be taxed in Georgia as a corporation rather than myself as a resident? Which would then void the 0% tax on foreign income and subject it to 15%?

Thank you, you're best placed to answer and I'm glad you can confirm. So the set up in Romania is not so bad. Do you pay any VAT on advertising in countries outside of Romania? Just wondering. Have you found any solution to the VAT on ad spend? I'm thinking it will only be waived if you have a...

It's actually called a double tax treaty only to determine how double tax will be treated, it does not necessarily mean there will not be tax in two countries. It is only the resolution of that double tax. If you read the treaty between Romania and USA in regards to royalties, it clearly says it...

In regards to this comment, of a $500k investment not requiring any stay, if I then stay outside of Georgia, would I not then become tax resident by spending more than 183+ days somewhere else, and lose the benefits of tax residency in Georgia? Not sure how that option works. Please elaborate.

Would this then also remove the VAT element of marketing spend for US ads? And could it also remove VAT on marketing spend in the UK? How do you not have to pay any tax on the royalty income in Romania? Is that genuinely the set up in Romania? The DTT agreement between the US and Romania says...

Thank you for making this clear and understandable for me. Much appreciated.

Thank you, that's something I learned today. I did not know that managing a company from another made it a tax resident in that country. I thought a company was a separate entity and regardless of who managed it and where they were, it was an entity of said country. My initial enquiry was not...

Under these circumstances would what the OP proposes work? Given the the LLC can be the beneficial owner, there would be 0%WHT and then NHR in Portugal 0% tax.

What about a Swiss company? Thank you. Considering the WHT is 10% and the tax on revenue will likely be 3% without any employees of the company, how likely is it that the tax credit will be 10% and equal a 3% offset and 7% refund? Or is it only likely to eliminate the 3% tax and the...

Ok thank you for this, it makes sense. If I positioned myself in this way, would this be correct: Establish a company in Hong Kong, input the beneficial owner on Amazon's/IRS tax interview questionnaire as Romania. Incur 10% WHT, no corp tax in Hong Kong, and then distribute profits from the...

I see, and as a Georgian resident, the WHT would be 0% but I would require a limited company to offer protection. Based on your comment of the beneficial owner being the determining factor of WHT under the treaties, how would I slot in the company in the middle? I can't be based in Georgia as it...