Residence in Monaco + US LLC

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You can't transfer all the profits from Estonia to Delaware without︂ paying taxes. I can confirm this 100%. Words of a tax advisor from Estonia.

I think i found the best place to setup a company with Monaco residency. Guernesey.

Guernesey and Monaco have tax agreements signed. It is one of the 33 countries that have︃ a treaty with Monaco.

What I have been able to see is that Guernsey is︄ perfect for Monaco in every way.

- 0% corporate tax.
- 0% on the distribution︅ of dividends to a resident of Monaco.
- A local director is required, which is︆ perfect for creating substance.
- It is easy to open a bank account for the︇ company with Lloyds or Barclays.
- It is an hour and a half by private︈ flight from Nice airport.
- It is in the European time zone, so it is︉ easier to work with banks than with one in the Caribbean.
- Simple hiring a︊ couple of part-time employees to create more substance.

Better than using structures in countries that︋ do not have agreements with Monaco and the territorial tax system that is not clear︌ (with a little research, although Gibraltar turns a blind eye, on paper you can claim︍ taxes on profits accumulated in bank accounts in Gibraltar, source: the Gibraltar government website).

I have to consult everything with local lawyers in Guernsey and Monaco in the next few︎ days, but it seems like the smartest solution.

I don't know how to send a PM 🙁
 
This doesn't mean merely transfering profits from the Estonian company, and is not really comparable⁠ to royalties structure.
In a partnership both parties contribute and are also exposed to the⁤ risks, and are entitled to the share of profit based on the agreement.
It could⁣ be the case that Estonian entity's contribution is mainly responsibility for invoicing and payment processing⁢ so naturally it should not be entitled to the major share of the profits.
Its a rather unconventional structure and hasn't been promoted much due to the complexity, but works︀ well in a tandem with a lower tax structure.
 
I understand now. However, it is less complicated to set up a company in a 0%︀ tax jurisdiction and residency in Monaco.
 
I will be confortable with something around 150-200k.
I take‍ the rent expense and the substance expenses of the company as a flat tax. And⁠ it still allows me to save most of the taxes I would have to pay⁤ in Estonia.
And in addition to the tax savings, I improve the quality of life⁣ because Monaco is much nicer to live in than Estonia.
 
Monaco taxation agreement approved by‌ EU

Although on paper Monaco does not care too much from which jurisdiction the funds‍ come from as long as their origin is legal, if in the future I decide⁠ not to continue in Monaco, the European Union banks will probably be concerned about the⁤ origin of the funds received. in Monaco. Or maybe not, I don't know.

But it⁣ is better to use jurisdictions that have tax treaties with Monaco, so that everything is⁢ more transparent to the West.

Suppose that when I am 60 years old, I get︀ tired of living in Monaco and decide to go to my home country. I suppose︁ it would be better to declare in compliance with the banks in my country that︂ the funds all arrived following tax agreements between countries.

And also, if Monaco in the︃ future, due to pressure from the West, decides to follow the CFC rules, it is︄ better to operate with a country with a double taxation agreement.

Monaco has a corporate︅ tax of 26.5% on companies resident in Monaco in which the origin of more than︆ 75% of the income occurs outside of Monaco. Just what my company is.

Bahamas and︇ Guernsey are the only two jurisdictions with which Monaco has a tax treaty that have︈ 0% corporate tax and 0% dividend distribution.

Guernsey is closer than the Bahamas, although both︉ would work the same. It's just the convenience of being able to take an hour︊ and a half flight and be there, in case you need to do some business︋ for the company.
 
2Checkout works with company in Guernsey.

Anyway, I even think I can‍ use Stripe and other processors with the following structure.

US LLC which is a subsidiary⁠ of a company in Guernsey.

But I would need to consult with an advisor if⁤ this is possible, I think so. USA allows ownership of an LLC by a foreign⁣ company.
 
DTAA would not shield you against CFC rules. Better to go with a Gibraltar entity‌ for half the price of a Guernsey + US LLC structure.
 
There is no reason to bank in Gibraltar, and‍ that is also incorrect. It's irrelevant if the funds are remitted to Gibraltar or not,⁠ corporate tax is applied only on Gibraltar sourced income.

If you want, open a thread⁤ where we can compare Guernsey and Gibraltar companies. I'm interested too.

In general, you will⁣ have access to more EMIs with a Gibraltar company, and there are also no substance⁢ requirements meaning less bureaucracy. AFAIK you can always redomicile the company to Guernsey if needed.︀
 
Income Tax Office

I think you overlook a lot of details.

1. In Gibraltar, businesses that⁢ exceed 1M in profits are subject to audit. Which is my situation. So the difference︀ in maintenance is not as cheap as you mention compared to other jurisdictions. Saying that︁ I am fine auditing my business, but only as a fact that is never mentioned.︂

2. In no official source of the Gibraltar government do I find that companies are︃ only subject to corporate tax in Gibraltar for income generated from a Gibraltar source, nor︄ that profits originating abroad are exempt from taxes even if they are transferred to bank︅ accounts in Gibraltar . What I do find is that companies in Gibraltar are subject︆ to corporate tax, but nowhere are those exemptions that are mentioned.

3. Thinking about savings︇ in incorporation and maintenance expenses as something positive for choosing the jurisdiction makes little sense︈ to me. Because they are a tiny part. I have greater savings depending on the︉ commissions charged by one payment processor or another. And that doesn't give me too much︊ of a headache either, because there are no substantial differences.

4. I will not take︋ the information provided by a provider of business formation in Gibraltar as 100% valid after︌ personal experiences. I have emails from Free Zones in Dubai assuring that the 9% corporate︍ tax is only paid by companies that do locally, when we all know today that︎ this is not the case.

There may be loopholes in Gibraltar that allow you to️ look the other way and not pay corporate tax. And even the Gibraltar government does‌ not make much effort in this regard.

But if there is a law that says‍ that a corporation tax is paid at 12.5%, I also want to see clearly the⁠ points where the Gibraltar government mentions exemptions. I don't want to be like a monkey⁤ dancing on blades, because in the future the tears may come.

In other jurisdictions where⁣ 0% corporate tax and 0% dividend distribution are clear, the risk is lower. Because the⁢ law is clear.

The reason to bank income in Gibraltar is because most payment processors︀ do not allow funds to be collected into bank accounts other than the country of︁ origin. With the exception of the EU. Gibraltar is not in the EU.
 
Probably nothing is better than 0%. You will be able to reinvest more in your‍ business and boost growth.
A flat tax is when all taxable income is subject to the⁢ same tax rate, regardless of income level or assets; in this case, it's more like︀ a fixed expense.

Take a moment to think about if your income will multiply 10x︁ or 100x.

The fixed expenses will start being increasingly less important.
 
Well, I take the rent and substance expenses as if they were a⁣ flat tax. Because I know what it's going to cost me every year.

I agree⁢ with you. And that's what I wrote. Having a fixed expense is not important to︀ me, that's why I don't mind paying rent in Monaco or substance in a company.︁ That doesn't change the business bill 10x or 100x.

A tax of 5% or any︂ other amount, yes.
 
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