Armenia and Georgia USSR - US tax treaty on royalties?

[alexXx9]

Hi,
I receive royalties from the US (Amazon KDP), I Moved two years ago to mexico but i don't want to stay here anymore.
Looking for alternatives and I was thinking Georgia might be a good location given the unique USSR - US tax treaty with no LoB on royalties.

I was browsing around and noticed that also armenia still have this deal according to the IRS website: https://www.irs.gov/businesses/international-businesses/armenia-tax-treaty-documents

Same thing for Georgia: https://www.irs.gov/businesses/international-businesses/georgia-tax-treaty-documents

However, when chatting with ChatGPT it does says that it is not the case anymore and that i wouldn't be able to claim the Tax treaty benefits by filling the W8-BEN-E or W8-BEN with a georgian ID.

Can anyone confirm which one is the truth?

Another option i was considering, since I have a vietnamese girlfriend is to do this:
Georgia LLC + Director and I'd be the shareholder. If any new books will be published, I'll delegate all the work to the director.

In this way, if i keep the profit into the company, I'd pay no taxes until distribution, in the meantime i can invest, accumulate $$, buy crypto, stocks, real estate, even in other countries, while compounding the capital.
As a shareholder, I'd just withdraw the money I need, and I'd pay 15% CIT + 5% WTH in Georgia + 5% in Vietnam.
Vietnam has a worldwide income taxation, but apparently you get taxed only on distributed income on the personal level, the LLC would be a company [according to different AI Chat, more research is needed on this]

I was thinking to try to apply this with either armenia or georgia + vietnam. if not applicable, i can stay 6 months+ year in georgia.

How stable is this setup? what might be the shortcomings? Any hypothesis on when and IF georgia might try to renegotiate the treaty with the US?
any alternative?

 

[daniels27]

Both Armenia and Georgia would do the job. But most people cost Georgia as such‌ royalty income is not taxed in Georgia while it is taxable in Armenia to my‍ understanding (both on a personal level). If you don't live in Georgia and use a⁠ Georgian LLC, your royalties are taxable at 15% (CIT) and there are also withholding taxes.⁤

Main question is where you want to live. Of course Georgia is 0% and cheapest⁣ in your case. Some like it, some not.

 

[alexXx9]

The withholding part is something that i still can't see a clear response about.
I had two video meetings with incorporation services business and both of them couldn't reply if‌ the US-Georgia tax treaty can actually work and if i can effectively benefits from the‍ tax treaty yes or not.

How can you be the sales person of an incorporation⁠ business and not know if the US-Georgia treaty still applies and if you can claim⁤ tax treaty or not! DOes anyone has had any experience with this? Can someone acutally⁣ fill the W8-BEN-E and claim treaty benefits with georgia yes or no?

 

[Marzio]

It's very easy to verify.

Create a fake google adsense⁤ account and put a random georgian address + tax id. If google will show 0%⁣ tax on royalties you'll know the treaty is valid (which it is to my knowledge).⁢