Question Jurisdiction structure with 0-10% taxes

Status
Not open for further replies.

alexkors

New Member
Jan 26, 2025
5
0
161
Hi everyone!
I'm new here and looking for help from the community to figure out the right direction to go. After a few days of research and calls with different providers, my brain is about to explode 😵

My goal:
To set up a structure that's legal, cost-efficient, and optimized for low taxes and maintenance. I'm happy to pay taxes, but if there's a legal way to pay less ”” why not?

About the business:
  • We run a completely legal and transparent online advertising agency
  • Main clients are from the US, Hong Kong, UAE, and EU (CY/NL)
  • We promote online services and app games (no gambling or other stuff)
  • UAE is not a great option for us ”” I see growing issues with USD transfers to/from there

Current setup:
  • Back office: Our team is based in Tajikistan, under a local company that's purely operational and doesn't generate profit (just covers expenses)
  • Hong Kong company: Signs client contracts, receives revenue, and pays for ads (Meta, Google, etc.). No employees, I'm the only director. Offshore status (no business or revenue in HK)
  • My personal status: I'm a Cyprus tax resident with non-dom status, holding Tajikistan and Grenada passports
  • Revenue and profit fluctuate, but roughly: $100k/month revenue, $20k/month profit

Questions:
1) Some of our clients don't want to pay the Hong Kong company
(due to their own compliance/offshore concerns), so we need an additional structure outside HK to:
  • Receive payments
  • Sign contracts
  • Diversify risks (e.g., in case Meta freezes our Business Manager)
Options I've considered:
a) UK LLP

Find a second partner or use a HK company, because of the pass-through taxation and non dome I can get 0% corporate tax and access to a large number of good EMIs.
Inexpensive service, but I can't have clients from Cyprus (otherwise there will be a pass-through income in Cyprus for me as an individual). Correct?

b) Singapore (non-resident company)
There is quite little information and apparently the jurisdiction/providers doesn't advertise this opportunity (or is it not relevant?), but as I understand it, there is an opportunity to get 0% tax on income/clients from outside Singapore if we don't have substence/clients there (for clients from Singapore, we will be able to use our HK company).
But there is a risk of recognizing this Singapore company by the beneficiary (me) as a tax resident of Cyprus and, accordingly, Cyprus corporate taxes apply + possible problems with withholding tax for clients from other countries? (not transparent for me, maybe I'm wrong).
Difficulties with banks/EMI (you can't have Singapore accounts), more expensive setup, maintenance, audits, and accounting.

c) Classic offshore (BVI, Seychelles, Panama, etc.)
  • Possibly cheaper and easier in terms of audit and compliance
  • BUT: Harder to get reliable banking/EMIs
  • Same as in Singapore, Cyprus authorities may treat it as managed from Cyprus = taxable locally and apply Cyprus corp taxes, and non-dome status doesn't help.

2) If none of the above options work as a simple one-layer structure, maybe I need something more complex?
Like setting up a virtual or real office/utility bills/staff in another country with low local corp taxes, or using my Grenadian passport somehow?

Last edited: May 2, 2025
 
alexkors said:
Yes, might be, but since most of our clients are from the US it's not so useful.

Anyway Cyprus authorities could tax US LLC (as managed and controlled from Cyprus) with corporate income tax at 12.5%, right?

Any ideas how to make this tax lower?
Click to expand...
Yes, they could.

Do you live in Cyprus? If you have it only as a paper solution, get a residency in a country with more relaxed laws (Paraguay, Panama...), and you can work with a US LLC + BVI/Panama company setup.
 
NewHorizonsParaguay said:
Yes, they could.

Do you live in Cyprus? If you have it only as a paper solution, get a residency in a country with more relaxed laws (Paraguay, Panama...), and you can work with a US LLC + BVI/Panama company setup.
Click to expand...
Yes, I live in Cyprus.

You mean get a Paraguay/Panama residency card, set up BVI/Panama on this residency, then set up US LLC with BVI/Panama ownership and pass-through taxation?
Sounds interesting.

And just in case of future dividend payments, is it not a good idea to get dividends from this structure to Cyprus as an individual? (they still could say it's controlled from Cyprus, correct?)
Or it's fine?

I mean, if with all these movements we still can get buttpain, maybe 12.5% is also ok 🙄
 
alexkors said:
Yes, I live in Cyprus.

You mean get a Paraguay/Panama residency card, set up BVI/Panama on this residency, then set up US LLC with BVI/Panama ownership and pass-through taxation?
Sounds interesting.

And just in case of future dividend payments, is it not a good idea to get dividends from this structure to Cyprus as an individual? (they still could say it's controlled from Cyprus, correct?)
Or it's fine?

I mean, if with all these movements we still can get buttpain, maybe 12.5% is also ok 🙄
Click to expand...
If you live in Cyprus, being a resident elsewhere does not strip you of the duty to pay taxes on pass-through income from a US LLC in Cyprus.

The other question is. If your clients do have problem with payments to jurisdiction as Hong Kong, how different it would be if it is Singapore / BVI / Panama, internationally known tax havens?
 
NewHorizonsParaguay said:
If you live in Cyprus, being a resident elsewhere does not strip you of the duty to pay taxes on pass-through income from a US LLC in Cyprus.

The other question is. If your clients do have problem with payments to jurisdiction as Hong Kong, how different it would be if it is Singapore / BVI / Panama, internationally known tax havens?
Click to expand...
No, the only problem with paying through Hong Kong is when our counterparties are also in Hong Kong (according to the law, you can get an exemption from taxation of foreign income only if you do not have an office and counterparties in Hong Kong).

Regarding US LLC with Cyprus residency. Cyprus has non dome benefits, as I understand, if I only beneficiary and all management decisions made outside of the Cyprus company can't be taxed with Cyprus corporate tax rules and I can get dividends with 0% tax with these non dome benefits.
 
Status
Not open for further replies.

JohnnyDoe.is is an uncensored discussion forum
focused on free speech,
independent thinking, and controversial ideas.
Everyone is responsible for their own words.

Quick Navigation

User Menu