10M.+ optimization tax residency when you have 3/4 bases.

[yngmind]

I wonder why no one has mentioned the Georgian High Net Tax Residency Certificate here,

The High Net Worth Georgian Tax Residency program is a unique opportunity for those with an income over 200,000 GEL (approx. 80,000 USD) or personal assets in excess of 3 Million GEL (approx. 1,200,000 USD) to claim tax residency in Georgia without even having to step foot in the country.

https://expathub.ge/high-net-worth-program-georgian-tax-residency/

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I'm not a tax advisor, so please don't consider my posts here as tax advice. Always seek a professional opinion.
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[Meta]

yngmind said:
I wonder why no one has mentioned the Georgian High Net Tax Residency Certificate here,

The High Net Worth Georgian Tax Residency program is a unique opportunity for those with an income over 200,000 GEL (approx. 80,000 USD) or personal assets in excess of 3 Million GEL (approx. 1,200,000 USD) to claim tax residency in Georgia without even having to step foot in the country.

https://expathub.ge/high-net-worth-program-georgian-tax-residency/
Click to expand...

It was amended in 2023 (as explained in the page linked), now it also requires investment of half of million USD into Georgia, so it's less attractive than before.

 

[daniels27]

We talked about this in other threads before. It is in most cases a useless paper.

You could claim treaty benefits but probably will fall the your breaker rules. Also, the other country will most likely not accept your claim if you cannot show presence there.

[COLOR=#f4ff81] B [/COLOR]

Post in thread 'Tax residency in Georgia while living in 2 European countries?'​

Nov 13, 2023

Don said:
Can you provide an example of the HNWI certificate?
Click to expand...

Every tax authority on Planet Earth will laugh about this piece of paper.

• backpacker

[COLOR=#ff9e80] R [/COLOR]

Post in thread 'Tax residency in Georgia while living in 2 European countries?'​

Sep 19, 2024
I must confess it seems that I was wrong about the Georgian HNWI certificate. It seems like it can be used for tax treaty benefits. The OECD model treaty only excludes residents that are becoming LIMITED tax residents due to income or capital situated in that country. This is not the case with Georgia, you really do get unlimited tax liability it seems. Very strange that OECD chose to include this into new tax treaties. However, I would never go that route anyways

• Revoltec

Last edited: Jan 24, 2025

 

[Don]

daniels27 said:
We talked about this in other threads before. It is in most cases a useless paper.

You could claim treaty benefits but probably will fall the your breaker rules. Also, the other country will most likely not accept your claim if you cannot show presence there.

[COLOR=#f4ff81] B [/COLOR]

Post in thread 'Tax residency in Georgia while living in 2 European countries?'​

Nov 13, 2023

Don said:
Can you provide an example of the HNWI certificate?
Click to expand...

Every tax authority on Planet Earth will laugh about this piece of paper.

• backpacker

[COLOR=#ff9e80] R [/COLOR]

Post in thread 'Tax residency in Georgia while living in 2 European countries?'​

Sep 19, 2024
I must confess it seems that I was wrong about the Georgian HNWI certificate. It seems like it can be used for tax treaty benefits. The OECD model treaty only excludes residents that are becoming LIMITED tax residents due to income or capital situated in that country. This is not the case with Georgia, you really do get unlimited tax liability it seems. Very strange that OECD chose to include this into new tax treaties. However, I would never go that route anyways

• Revoltec

Click to expand...

It should work well if you have investments abroad in a country where you have never lived.

One common example I can think of would be claiming back overpaid tax from Belgium, related to your Wise cashback earnings.

Wise Europe operates within the tax jurisdiction of Belgium, where cashback is liable for 30% withholding tax. However, treaty rate is 10%, so provided you get this certificate you can submit relevant application and claim back the tax.

 

[daniels27]

Maybe also US royalties then?

But in the thread between you and backpacker I linked, he claimed that the certificate would not work as it is a different one. Still, in the other thread Revoltec claimed the opposite.

Without upsetting to many here with my question, what is now with this certificate? Could you claim benefits like the US royalties tax-free (given that no other country claims any tax from you)?

Maybe an option for Leo Vanguard then?
https://www.offshorecorptalk.com/th...itius-structure-2-1-effective-tax-rate.46119/

Last edited: Jan 24, 2025

 

[Don]

daniels27 said:
Ok yes. That could work. Maybe also US royalties then?
Click to expand...

generally the risk could be Limitation of Benefits (LOB), but USSR - US treaty doesn't have that.
LOB clause restricts the availability of treaty benefits to entities that have a genuine connection to the state and are not just set up to exploit the treaty's benefits, thereby guarding against misuse by third-country residents.

 

[daniels27]

Don said:
generally the risk could be Limitation of Benefits (LOB), but USSR - US treaty doesn't have that.
LOB clause restricts the availability of treaty benefits to entities that have a genuine connection to the state and are not just set up to exploit the treaty's benefits, thereby guarding against misuse by third-country residents.
Click to expand...

Yes. The Belgium one seems to be missing that too.

 

[hlepic211]

daniels27 said:
We talked about this in other threads before. It is in most cases a useless paper.

You could claim treaty benefits but probably will fall the your breaker rules. Also, the other country will most likely not accept your claim if you cannot show presence there.

[COLOR=#f4ff81] B [/COLOR]

Post in thread 'Tax residency in Georgia while living in 2 European countries?'​

Nov 13, 2023

Don said:
Can you provide an example of the HNWI certificate?
Click to expand...

Every tax authority on Planet Earth will laugh about this piece of paper.

• backpacker

[COLOR=#ff9e80] R [/COLOR]

Post in thread 'Tax residency in Georgia while living in 2 European countries?'​

Sep 19, 2024
I must confess it seems that I was wrong about the Georgian HNWI certificate. It seems like it can be used for tax treaty benefits. The OECD model treaty only excludes residents that are becoming LIMITED tax residents due to income or capital situated in that country. This is not the case with Georgia, you really do get unlimited tax liability it seems. Very strange that OECD chose to include this into new tax treaties. However, I would never go that route anyways

• Revoltec

Click to expand...

100%

This will work for banks, EMIs, etc., basically paper residence. This can work for a while but remember you will not be 100% secure.

 

[JustAnotherNomad]

So you have to show Georgian assets? What does that mean?

 

[kekmaw]

JustAnotherNomad said:
So you have to show Georgian assets? What does that mean?
Click to expand...

Could be real estate, a brokers account from Georgia or even from a bank account in Georgia. It can be transferred out of Georgia after the application.

 

[yngmind]

Apparently, the top country that gets those HNWI tax residencies in Georgia is Germany, so it must work for them

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[JustAnotherNomad]

If you can transfer out the assets, then how long is the tax residency valid for?

 

[JustAnotherNomad]

yngmind said:
Apparently, the top country that gets those HNWI tax residencies in Georgia is Germany, so it must work for them
Click to expand...

That probably doesn't mean much:

* Probably the number of people getting this tax residency is low, so not difficult to get to the top there (if it's only a handful of people per nationality)
* Germany has a much larger population than, say, Luxembourg
* The certificate is of little use to Americans
* Could be due to a successful German marketer (likewise products marketed by American marketers like Andrew Handerson will be popular with Americans)
* Many people overestimate the usefulness of tax residency certificates

 

[kekmaw]

JustAnotherNomad said:
If you can transfer out the assets, then how long is the tax residency valid for?
Click to expand...

You renew it yearly.

 

[JustAnotherNomad]

So you basically have to keep 500k in Georgia.

 

[JohnnyDoe]

JustAnotherNomad said:
So you basically have to keep 500k in Georgia.
Click to expand...

Most likely even when you no longer want to do that:
Post in thread 'Terabank Georgia'
https://www.offshorecorptalk.com/threads/terabank-georgia.35375/post-195653

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@JohnnyDoe ”“ Your #1 Source for Guidance in Different Offshore Fields​

 

[kekmaw]

JustAnotherNomad said:
So you basically have to keep 500k in Georgia.
Click to expand...

As long as you have no issues with sending wires in and out of Georgia you can move it in before the application and out after it and rinse and repeat next year.

 

[JustAnotherNomad]

500k wires in and out of Georgia, what could possibly go wrong...

 

[wellington]

Just a note on Thailand.

1) Lot(s) of kidnappings of late (mainly Chinese/Russian etc)
2) Bumped into someone a few months ago that i had dealings with that i learned after many years to have a unethical position towards wealth generation - anyway - since that point had random car(s) outside my home (private road - semi-secure - no reason to enter), and bumped into him a few times and had remarks about "this or that". (raised security).

So recognise people will go beyond a certain line in the sand if they see an opportunity.

 

[JustAnotherNomad]

Wow, would that be locals or other expats one would have to worry about?