Best country for lowest tax - Online SaaS Business

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Decided to open US LLC.
Anyway I have to‍ pay in Georgia, as all the job is done from Georgia.
 
hold on.

What if somebody‍ gets a HNWI Georgian residency with georgian tax certificate and does the work from outside⁠ georgia? (for example UAE).

Let's imagine another EU country is challenging your residence, based on⁤ Georgia-EU country treaty most probably a tie breaking rule will be a permanent home.

You can have an apartment rented in Georgia for 100usd/month so you have tax residence certificate⁣ from GE and qualify also under the DTA. At that point the US LLC distribution⁢ will be considered as foreign income according to the georgian tax code.

Any comment is︀ appreciated.
 
They also use cfc︀ rules, most of europe uses. Meaning the company would have to be controlled by the︁ director from the country where it is incorporated or would just handled like Georgien company︂ tax wise.
 
this seems more a⁠ matter of residence of the company (Place of Effective Management criteria).
i believe you are⁤ mixing 3 concepts
1) residence of the company (based on internal legislation and on DTAs)⁣
2) presence of permanent establishment (again internal legislation and specific DTA)
3) CFC which concerns⁢ usually a passive income company that becomes disregarded for tax purposes in the owner's taxable︀ base

as far as i know, georgia has no CFC legislation in place. While other︁ points 1) and 2) require a case by case analysis
 
There is a German Youtuber that moved there and got a︀ real Tax Accountant involved that said, they have basically have the same regulation there they︁ just call it different.
 
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