I am thinking the same....there is no official guideline there which mention this directly or indirectly
Remote worker travelling the world - setup
- Thread starter 12345
- Start date
- Status
T
thomasparra
Guest
Yes, and the tax certificate will probably be not enough with regards to your home country. You can get that 90 day based tax certificate in UAE but your home country might still ask for more evidence you are actually living there (apartment lease, utility bills for instance).
Yes, and the tax certificate will probably be not enough with regards︈ to your home country. You can get that 90 day based tax certificate in UAE︉ but your home country might still ask for more evidence you are actually living there︊ (apartment lease, utility bills for instance).
Poland. He doesn't have kids, wife or any property in the country
Wow so︆ is he forced to spend 180 days in Bulgara / Romania or Thailand ? Wow︇ then I think it's better to just pay the tax in his home country
What if he deregisters and doesn't register for tax residency elsewhere, is it very big of︈ a problem? He is fine with using Wise/Zen/Revolut only as a bank
Wow so︆ is he forced to spend 180 days in Bulgara / Romania or Thailand ? Wow︇ then I think it's better to just pay the tax in his home country
What if he deregisters and doesn't register for tax residency elsewhere, is it very big of︈ a problem? He is fine with using Wise/Zen/Revolut only as a bank
I see. What I mentioned seems to be a resident certificate, without︈ the TAX. Though it's usable in Thailand for many things, like bank accounts etc.
https://thailawonline.com/certificate-residence-thailand/
For all I know, Germany specifically has a system where one can unregister himself as︉ resident and move to a different country, and immediately ceases to be a tax resident.︊ No need for any 180 days things.
One shouldn't keep any property in Germany then,︋ or have any other ties, and not visit for more than 2 weeks per year,︌ no rent a property, etc. It gets more complicated if one already has a company︍ (exit taxation). But for many people with no assets or wife left in Germany, just︎ signing out at the city office and moving away is enough to be free from️ their tax authorities.
https://thailawonline.com/certificate-residence-thailand/
For all I know, Germany specifically has a system where one can unregister himself as︉ resident and move to a different country, and immediately ceases to be a tax resident.︊ No need for any 180 days things.
One shouldn't keep any property in Germany then,︋ or have any other ties, and not visit for more than 2 weeks per year,︌ no rent a property, etc. It gets more complicated if one already has a company︍ (exit taxation). But for many people with no assets or wife left in Germany, just︎ signing out at the city office and moving away is enough to be free from️ their tax authorities.
It depends on how much he makes. Yes, it's probably better to stay a Polish tax resident if income doesn't exceed at least $70k IMO.
You have to keep in mind that forfeiting an EU tax residency comes with other costs: maintaining a company,︀ health insurance, etc. so if income is not large enough it doesn't make sense.
Deregistering and not becoming a tax resident anywhere else is possible in theory, but it's not︁ recommended, as it comes with additional challenges (plus the ones mentioned above).
Note also that︂ Poland has an exit tax for assets exceeding 4M PLN, so again, it has to︃ be kept into account if his profits start increasing and piling up.
You have to keep in mind that forfeiting an EU tax residency comes with other costs: maintaining a company,︀ health insurance, etc. so if income is not large enough it doesn't make sense.
Deregistering and not becoming a tax resident anywhere else is possible in theory, but it's not︁ recommended, as it comes with additional challenges (plus the ones mentioned above).
Note also that︂ Poland has an exit tax for assets exceeding 4M PLN, so again, it has to︃ be kept into account if his profits start increasing and piling up.
Here is an article of our auditors at Deloitte where they state that dividends are not taxed
https://www2.deloitte.com/content/d...ttl-tax-unitedarabemirateshighlights-2021.pdf
https://www2.deloitte.com/content/d...ttl-tax-unitedarabemirateshighlights-2021.pdf
I understand that, but as you know, an LLC does not distribute dividends. There are no shareholders in an LLC to distribute dividends to. Instead, LLCs have members. Under US law, income from an LLC is considered normal income (i.e. not dividends) for the members.
LLCs as hybrids of partnerships and corporations.
Some jurisdictions don't recognise LLCs as hybrids and instead consider them corporations. Canada is an example of this, where LLCs become taxable persons and, as such, they distribute dividends and︀ not personal income. Many other jurisdictions lack specific recognition or recognize LLCs as partnerships (pass-through︁ entities).
So I was wondering if there has been a ruling or guidance note issued︂ in UAE whereby LLCs are determined to be corporations that issue dividends rather than distribute︃ income.
LLCs as hybrids of partnerships and corporations.
Some jurisdictions don't recognise LLCs as hybrids and instead consider them corporations. Canada is an example of this, where LLCs become taxable persons and, as such, they distribute dividends and︀ not personal income. Many other jurisdictions lack specific recognition or recognize LLCs as partnerships (pass-through︁ entities).
So I was wondering if there has been a ruling or guidance note issued︂ in UAE whereby LLCs are determined to be corporations that issue dividends rather than distribute︃ income.
You can still maintain a company in the EU though even after no longer being an EU tax resident, just not in a country where a company would create ties/make you a tax resident. There are many options, Ireland, Estonia etc.
And for health insurance, there are actually ways around that too. You can establish residency in︀ an EU country, get an EHIC card , typically valid for 5 years, and then︁ leave. Then you'll get health care in all EU countries (plus Switzerland) except in the︂ country that issued the EHIC card. It doesnt matter if you are no longer a︃ resident of the country that issued the card.
And you can also always re establish︄ residency in the EU and get health care - it s not always immediate though.︅
And anyway, there is great private health insurance, and when paying for it yourself it︆ becomes very clear how enormously wasteful government provided health care is.
And for health insurance, there are actually ways around that too. You can establish residency in︀ an EU country, get an EHIC card , typically valid for 5 years, and then︁ leave. Then you'll get health care in all EU countries (plus Switzerland) except in the︂ country that issued the EHIC card. It doesnt matter if you are no longer a︃ resident of the country that issued the card.
And you can also always re establish︄ residency in the EU and get health care - it s not always immediate though.︅
And anyway, there is great private health insurance, and when paying for it yourself it︆ becomes very clear how enormously wasteful government provided health care is.
You have︂ to look at it from the UAE side since UAE considers LLC's as an entity.︃ This means profit distribution are dividends. UAE does not care if it is dividends that︄ come in, from the US part it is only important that you are tax resident︅ of UAE.
I don't think we know how the UAE treats US LLC's yet.
If they are treated as an entity , ie a foreign juridical person, then if they have PE in the UAE they have to get registered in the UAE and pay 9% on profits.
If they are not treated︀ as an entity, ie it's just like a natural person in the UAE earning money,︁ then there is no tax or need to register up to 1M AED in turnover.︂
If they are treated as an entity , ie a foreign juridical person, then if they have PE in the UAE they have to get registered in the UAE and pay 9% on profits.
If they are not treated︀ as an entity, ie it's just like a natural person in the UAE earning money,︁ then there is no tax or need to register up to 1M AED in turnover.︂
Exactly. That's what I'm after. Until there is a definite ruling or guidance note issued, we don't know how UAE will treat income from US LLCs.
US LLCs are entities. I'm not aware of︀ any jurisdiction that doesn't recognize LLCs as entities. But, for tax purposes, are they opaque︁ entities or transparent entities? The answer determines at which point tax kicks in, as it︂ affects where the entity is tax resident and/or has a PE.
US LLCs are entities. I'm not aware of︀ any jurisdiction that doesn't recognize LLCs as entities. But, for tax purposes, are they opaque︁ entities or transparent entities? The answer determines at which point tax kicks in, as it︂ affects where the entity is tax resident and/or has a PE.
The UAE clarifies in its corporate tax FAQ that foreign "incorporated partnerships" (entities that the UAE recognizes are treated as transparent for tax purposes by the country they are formed in) are treated as opaque: They are subject to UAE corporate tax if they are managed and controlled from the UAE and/or have permanent establishment in the UAE. In other words, the same rules apply as for a foreign corporation.
I would be extremely surprised if LLCs were treated any different.
I would be extremely surprised if LLCs were treated any different.
- Status