Company structure for AmazonUS and transfer pricing scrutiny

[sportsbyte]

Hello all,

I've been lurking around for a bit and want to see if this would work, and gain some insight in so far as setting up a proper operation for tax reduction.

Some key information:

• I am a resident of Country A (CA), as long as I am a resident, I am taxed on Worldwide Income.
• I have a business incorporated in CA (CACorp) and also a holding company (CAHolding)
• I have a business incorporated in the BVI (BVICorp) with me as UBO and a nominee director/shareholder.
• I want to set up an Amazon US seller account using a business in Cyprus or Georgia, as they have a tax treaty with the US to disregard the 30% WHT and Amazon allows seller accounts for those two countries.

So what I intend to do:

1. Incorporate either in Cyprus or Georgia (NewCorp) using a nominee director. Is there a way I can hide the UBO? I saw a post from @Sols where a UK LLP can be used to control the NewCorp through a contract / exclusive sales agreement of sorts and can basically control NewCorp without exposing myself, as nominee will also be the UBO. If this works, I would also incorporate a UK LLP (UKCorp) with my information as UBO and control NewCorp this way.
2. Set up a bank account in Cyprus/ Georgia with NewCorp. Nominee would have full signing authority, so I would probably need a bulletproof agreement as to prevent embezzlement or getting scammed.
3. As there is a tax treaty, there won't be WHT from AmazonUS.

Now in order to reduce my tax liabilities, NewCorp will be selling on AmazonUS in addition to selling wholesale to CACorp at higher costs (transfer pricing, so the structure must pass scrutiny and must pass as arms-length transaction.). NewCorp will then buy goods at yet another increased cost from BVICorp (which I am UBO) which ultimately buys the goods at its true manufactured price. In addition to these, BVICorp would hold trademarks which later on would bill NewCorp and CACorp royalty/IP-usage fees.

BVICorp and my resident country has a tax treaty, basically can repatriate all profits to the parent company (CAHolding) and not pay tax as profits generated has already been taxed in BVI (even though its 0%). I intend to repatriate a fair share back and purchase real estate, etc...

Now the thing is, as the parent company, can my resident tax country force me to handover internal invoices/transactions of the BVICorp of which I am only owner and not director (as I have a nominee director/shareholder setup)? The next question would be to setup a bank account for the BVI, which hasn't been done.

Thoughts on this?

Thanks!