Tax residency in UK

[Marzio]

rdevalex said:
What profit is liable to country's CIT where PE is triggered?
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All income. The company is considered tax resident in that country because of management.

rdevalex said:
So, should US LLC pay CIT in this case despite such US LLC is treated as a transparent entity in a country where a manager taking decisions is a resident?
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Not where the manager is resident but where he is taking decisions.

Look i understand what you are trying to achieve and the only way to make it work is to make the LLC tax resident in a tax free jurisdiction or a low tax jurisdiction.

 

[rdevalex]

Understood. I just wanted to make sure that it doesn't matter how other countries treat US LLC - as a transparent or opaque entity. It looks like US LLC should always pay CIT in any country where a manager is taking decisions even though US LLC is teated as a transparent entity in that country.