Maltese Resident (Non-Dom) + US LLC (Delaware)
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sorry for the trivial question, how do you outsource operations outside of Malta?
do you mean taking offices and employees? in that case if you take offices and employees in the U.S. you become a resident there, so you will pay taxes in the U.S.?︀
do you mean taking offices and employees? in that case if you take offices and employees in the U.S. you become a resident there, so you will pay taxes in the U.S.?︀
Risk of what?
Of your company becoming tax resident in Malta?
It is exactly what resident non domiciled companies are all about!
I highly suggest you to open a new thead, group your ideas and explain your context because i don't understand what you want to achieve.
Of your company becoming tax resident in Malta?
It is exactly what resident non domiciled companies are all about!
I highly suggest you to open a new thead, group your ideas and explain your context because i don't understand what you want to achieve.
I have confirmed this, as a maltese non dom resident myself, Malta applies a domicile rule for companies based on INCORPORATION and not from where it is controlled or managed. Hence, you can control and manage your offshore company from malta, you and your company will only pay tax on the money that is remitted to malta. CFC rule kicks in only if your turnover is above 750k a year. This is completely legal and I have verified with many law firms plus you will find plenty of literature on this with KPMG, DELOITTE AND E&Y MALTA OFFICE. In my opinion, malta provides multiple structuring︀ and optimising opportunities. I am glad I left dubai.
As far as US LLC being managed and controlled from malta is concerned, I am in a similar situation, I verified that Malta treats US LLC as a corporation hence US LLC can also be used as a non dom company and you pay tax on the money you remit to malta. But please consult a good tax attorney in your case just to verify and dont take my advise as financial or tax advise. Goodluck.
What do CFC rules have to do with this? Do you have a Maltese Holding company?︁
According to PWC: "All companies incorporated in Malta are considered to be both domiciled and︂ resident in Malta. Other bodies of persons (including companies incorporated overseas) are considered to be︃ resident in Malta when the control and management of their business are exercised in the︄ country."
According to CFR: "It is worth noting that a company is considered to be︅ resident for tax purposes in Malta when the management and control of the company is︆ exercised in Malta."
Maybe link source of your claims as well? As far as I︇ can see everything you described is not what is being claimed by CFR.
According to PWC: "All companies incorporated in Malta are considered to be both domiciled and︂ resident in Malta. Other bodies of persons (including companies incorporated overseas) are considered to be︃ resident in Malta when the control and management of their business are exercised in the︄ country."
According to CFR: "It is worth noting that a company is considered to be︅ resident for tax purposes in Malta when the management and control of the company is︆ exercised in Malta."
Maybe link source of your claims as well? As far as I︇ can see everything you described is not what is being claimed by CFR.
https://taxsummaries.pwc.com/malta/corporate/taxes-on-corporate-income
https://www.ccmalta.com/publications/malta-taxation-of-resident-non-doms-entities
https://corriericilia.com/publications/resident-non-domiciled-companies
https://cfr.gov.mt/en/inlandrevenue/corporatetax/Pages/Corporate-Tax.aspx - CFR explanation on corporate residence and Taxation of companies not incorporated in malta.
Hope those links are sufficient to prove my statement. Its important to understand that domicile of companies is being determined by where it is incorporated and where the income is arising and whether it is being remitted. Goodluck.
https://www.ccmalta.com/publications/malta-taxation-of-resident-non-doms-entities
https://corriericilia.com/publications/resident-non-domiciled-companies
https://cfr.gov.mt/en/inlandrevenue/corporatetax/Pages/Corporate-Tax.aspx - CFR explanation on corporate residence and Taxation of companies not incorporated in malta.
Hope those links are sufficient to prove my statement. Its important to understand that domicile of companies is being determined by where it is incorporated and where the income is arising and whether it is being remitted. Goodluck.
Dear Mr Gus, I have sourced PWC itself for you︂ and the explanation of Non dom entity and its taxation and even sourced CFR for︃ you, Kindly read the full statements on the websites before commenting with aggressive suspicion. Good︄ day.
there is a tax treaty between the US and Malta. This︀ treaty helps to prevent double taxation on income earned by residents of one country in︁ the other.
However, it's important to note that the specific tax implications of your situation︂ can be complex and may vary depending on your individual circumstances
However, it's important to note that the specific tax implications of your situation︂ can be complex and may vary depending on your individual circumstances
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