Thai Resident Expat – Offshore Company Structure

[DigitalAffiliate]

Hello everyone, I have just upgraded my account to Gold Membership and have a question please: I am living full time in Thailand on the Thai Elite Visa (British expat). I understand Thailand operates a territorial tax system, where only funds remitted to Thailand are taxed. I am looking to do affiliate marketing (forex and crypto broker rebates paid in crypto USDT / BTC), trading courses and software sales (payments by card, PayPal+ crypto), and YouTube AdSense revenue. I do not need to remit the funds to Thailand and plan to reinvest the funds in stocks, futures and crypto overseas (US and Asia brokers).

I would like to minimize / eliminate any tax liability and am considering setting up an offshore entity / entities for this. Please can anyone advise which countries and structure you recommend? Others have recommended to me Nevis, The Cook Islands, Belize, Seychelles, BVI IBC, and US LLC.
I'm considering registering a US LLC for receiving YouTube AdSense revenue, trading course and software sales; and Nevis or Cook for receiving forex and crypto affiliate rebate commissions (payments in Crypto USDT / BTC). I understand the Forex brokers don't accept affiliate companies registered in US for compliance reasons. Does this setup work ok? Is it best to register the US LLC company in my own name, or in an offshore company name? The US LLC will need access to card processing, banking / EMI for sending funds to my brokers in US / Asia.

I am very grateful for any thoughts on the best way to set this up.

Last edited: Feb 26, 2024

 

[uplana]

First and foremost, I would find out which EMIs support some of the countries you mention there. Seychelles is a hot topic at the moment, and there are people claiming that it's possible to get an EMI for such a company. If that is correct and it's still easy to set up a company there as it was before, then that would be my best bet.

However, you should be aware that it's not as easy anymore to hide behind a company to avoid paying taxes! I don't know how it works with Thailand, but I know there are some knowledgeable members here who know something about it. @wellington @Jbb1 @jafo

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[wellington]

Believe i covered elsewhere.

As long as the company is completely overseas, a substance requirement isn't really needed as Thailand's territorial tax system focuses on remittance on a personal level, previously 1 tax yr matured, these days taxable regardless (except for those grandfathered in for their savings).

So for example.

John Doe owns a company in BVI, the company operates completely overseas, any operational staff are also oversea (exclude director/owner) and all business transactions are overseas.

John Doe recieves income/dividends.

He pays income tax on that, but the company isn't brought on-shore into Thailand just because John Doe resides within Thailand.

This process as per my discussion with the Thai revenue department will continue as is, except John Doe now pays tax on the remitted income, not income that isn't remitted.

Hope that helps.

 

[Marketint]

You mention also youtube/Adsense. Keep in mind that YouTube/adsense not payout to EMI accounts. Just some will work so far I know.

 

[DigitalAffiliate]

uplana said:
First and foremost, I would find out which EMIs support some of the countries you mention there. Seychelles is a hot topic at the moment, and there are people claiming that it's possible to get an EMI for such a company. If that is correct and it's still easy to set up a company there as it was before, then that would be my best bet.
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Thank you. Yes, it appears banking and EMIs are difficult with a Seychelles company. I would mostly be using the Seychelles company for receiving forex and crypto affiliate commission payments from the brokers in BTC / USDT which I will convert to fiat using EMI before reinvesting in stocks and futures. Al Salam Bank in Seychelles was mentioned in an earlier thread, also Verifo EMI. Did anyone have recent success using these, are there any others worth looking at? Will the banks/ EMI accept ”˜trading education' business in Seychelles, or would I need to use a cover website when setting this up? I'm planning to use a US LLC for selling the trading courses, trading software, and AdSensense.

wellington said:
Hope that helps.
Click to expand...

This is a huge help Wellington. Thank you!

Marketint said:
You mention also youtube/Adsense. Keep in mind that YouTube/adsense not payout to EMI accounts. Just some will work so far I know.
Click to expand...

If I use a US LLC and US bank for receiving Adsense revenue would YouTube withhold any tax from the earnings? I understand when setting up a US LLC you need to specify your principal places of business and related parties. Do I need an offshore holding company for the US LLC to avoid US tax deductions on AdSense?
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Just one further question: can anyone recommend the best stock / futures brokers, and crypto exchanges which support Seychelles companies? I want to reinvest in US and Asian stocks and futures, + crypto preferably in US / Asia. I use IBKR on my own account and very happy with them, but understand they don't accept Seychelles any more. Are there any decent alternatives?

 

[wellington]

What brokers allow crypto (out of curiosity)?

Ah see your follow on paragraph - on that no clue as surprised me even being mentioned.

 

[DigitalAffiliate]

wellington said:
What brokers allow crypto (out of curiosity)?
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IBKR has full size and micro futures on BTC and ETH. Kraken offers crypto futures perpetual contracts.

I'm trying to find a solution to access these markets using a Seychelles company. I understand IBKR no longer accepts Seychelles. I will check with Kraken. If anyone knows a decent stock and futures broker which will accept Seychelles company please post below. Thank you

Last edited: Feb 28, 2024

 

[DigitalAffiliate]

Looks like Kraken accepts Seychelles companies, but no 3rd party can wire transfer funds to the Kraken account. Still searching a decent futures broker and EMI for Seychelles company.

Does anyone know if I use a US LLC and US bank for receiving Adsense revenue, would YouTube withhold any tax?

I checked Thai tax treaty with US, according to Chat GPT only 5% withholding tax is deducted. What if I enter my Thai address for Adsense, but don't remit funds to Thailand, does that cap tax at 5%?

Last edited: Mar 1, 2024

 

[Marketint]

DigitalAffiliate said:
I checked Thai tax treaty with US, according to Chat GPT only 5% withholding tax is deducted. What if I enter my Thai address for Adsense, but don't remit funds to Thailand, does that cap tax at 5%?
Click to expand...

I don't know if they hold anything if you put Thai address. Maybe not. The problem is that you need to receive a PIN number what is sent by normal post office . It not always arrive . Probably also there is a lock to receive money on a bank account outside Thailand. This was the case until begin this year for most counties. Now you can receive for example money in Italy with a Adsense account in Spain. I am not sure how the situation now is with Thailand. Approval can be hard. Especially for Adsense for content sites. YouTube is more easy.

 

[DigitalAffiliate]

Marketint said:
I don't know if they hold anything if you put Thai address. Maybe not. The problem is that you need to receive a PIN number what is sent by normal post office . It not always arrive . Probably also there is a lock to receive money on a bank account outside Thailand. This was the case until begin this year for most counties. Now you can receive for example money in Italy with a Adsense account in Spain. I am not sure how the situation now is with Thailand. Approval can be hard. Especially for Adsense for content sites. YouTube is more easy.
Click to expand...

Thanks Marketint. I have a bank registered in Singapore with my Thai address so that may work. Otherwise, if I use a US LLC does anyone know if YouTube Adsense will withhold tax as a non American non America resident?