SINGAPORE COMPANY TAXES ON FOREIGN INCOME IF REMITTED?

[Marzio]

Exactly, Uber is using SG as headquarter to⁠ receive divends tax free from Uber B.V.

Unless you have that kind of structure, SG⁤ is not your place.

You still "could" pull it off if your HK company is not considered a MNE︀ group ( A group that includes at least one entity or permanent establishment that is︁ not located or established in the jurisdiction of the ultimate parent entity of the group)︂

 

[bigbite100]

@Mike Forman and @marzio Thank you for︆ the information. I understand now, that Singapore will really not be possible and even Hongkong︇ might not be that clean/easy.

So basically the only alternatives would be to use the︈ Malta/UK solution, Dubai/RAK or "exotic" countries like Seychelles an so on?

 

[Marzio]

The best for you‍ as a CY resident would be using the Maltese resident non domciled company approach.

If you decide to move then Dubai freezone is best.

Seychelles is simply not relevant in⁠ this day and age.

 

[bigbite100]

What would be the reason to︀ use the UK Ltd company? Cant I just send the money from the US LLC︁ to the Maltese company?

I plan to stay in CY.
Dubai would not work in that case︄ or Malta better because its cheaper/easier?

 

[Marzio]

Because dealing with one company is simpler and with a UK LTD you will not⁠ have to remember to file form 5472.

If you don't care you can transfer profits⁤ from the US LLC to UK LTD resident in Malta.

Dubai setup⁢ would be more expensive.

 

[fshore]

Is it clear that Cyprus doesn't consider a US LLC as a corporation? Many other‌ countries do, and will treat the profits as dividends, even though the IRS doesn't consider‍ it as profits.

 

[Marzio]

@CyprusLawyer101 said once that US LLC isn't treated like a corporation in‍ Cyprus and i took this for granted but even in case US LLC would be⁠ treated like a company, by managing the US LLC from Cyprus he would create a⁤ PE in Cyprus so the result is the same.

 

[bigbite100]

Thats a good question. is it possible⁠ to find a valid answer to this and where? just a google search couldnt help..⁤ and i am not sure if it is written in law if the US LLC⁣ is treated as a corporation

 

[Marzio]

https://www.offshorecorptalk.com/threads/us-llc-cyprus-residency.28570/#post-213722
It was @CyprusLaw that said that, not @CyprusLawyer101 but the bottom line‌ is the same.

 

[bigbite100]

Hello @marzio , I would like to compare the⁤ costs. Do you provide a Dubai offshore dividend setup or can you recommend someone for⁣ that?

Thank you in advance

And why is Seychelles not relevant? They arent on the black list︂ country, company creation is very cheap and remote possible and there are also a few︃ fintechs /banks which accept the bank account. I know they dont have a good reputation,︄ but the "hard facts" speak for it or not?

 

[bigbite100]

@All Any opinions on why Seychelles is not relevant anymore? Always looking to learn something‌ new 🙂

 

[Mike Forman]

1)Rapidly get a free red flag for tax evasion‍ in Europe and possibly US (I have no experience with US) unless you are based⁠ in Asia.

2)As good as impossible to open a bank account (you can try Hong⁤ Kong and Singapore but would be even more difficult than a Hong Kong corporate account.⁣

If some European authority notices Seychelles = alarm tax evasion. It was on the EU⁢ blacklist last year and can end up there again at any time.

3) Requirement of︀ handing over your bookkeeping.

 

[bigbite100]

Thank you for the helpful information! Great explanation.

 

[Meta]

I'm wondering if it's the case for all/most zero-tax "classic offshore"⁢ jurisdictions, or just Seychelles. Is it the same with BVI/Cayman Islands, for example?

 

[Mike Forman]

That's with all the classic offshore, which have also lost their appeal as some have a‍ public register and require to file the accounting files.

At least using them in Europe.⁠ If you want to do transactions in Europe with those you need to add a⁤ layer, such as HK or SING company. In China, Hong Kong, Singapore offshore as BVI,⁣ Samoa, Seychelles etc are still accepted and BVI is very common as a holding, but⁢ hard to open a bank account