US LLC + Seychelles + Cyprus (nom-dom) or IP Box

[mmaestri]

Hi, I'm a software engineer and digital transformation consultant. My business consists of two streams: one from a SaaS product with recurring subscriptions and another from IT consulting with top 500 companies.

Passports: Italian, Brazilian, Swedish
Tax residency: Cyprus (nom dom)

My current setup is a US LLC with Mercury. However, we want to improve and reduce our tax burden. The possible ideas are:

1. US LLC owned by a Nevis/Seychelles IBC + distribute dividends (tax exempt) to me as tax resident in Cyprus via banks OR EMI
2. Cyprus Ltd IP Box with 2.5% tax

Any advice on these options?

Thanks

 

[Marzio]

What is your actual tax burden?

I'm asking because you are manaing a US LLC from‌ Cyprus and since Cyprus sees US LLCs as transparent entities you should be taxed at‍ PIT rates.

 

[mmaestri]

Yes that’s correct. I just moved here from a high tax country. But looking to‌ optimize it further.

 

[Marzio]

The easy "not so compliant" way is‍ to distribute profits from the US LLC as dividends so that they are tax free.⁠

It's not compliant but as of now Cyprus tax agency is not going after non⁤ doms.

The compliant way is to establish a Cyprus LTD, hire a manager, rent an⁣ office, invet in R&D activities to get access to the IP box and pay 2.5%⁢ on the SaaS business.

The consulting wouldn't be able to access the reduced rate.

You could interpose a Nevis company but the banking would be a nightmare and you will︀ also need an offshore manager so that Cyprus wouldn't claim you are managing things from︁ Cyprus (which you are LOL).

 

[CyprusLawyer101]

There are quite a few options available including what you are mentioning.
DIfferent approach may‌ be neccessary regarding your consulting work, but thw whole thing could in fact be optimized‍ altogether without deviating substantially from your existing structure. Keeping things simple is paramount to focusing⁠ on your work.

 

[hcb]

@CyprusLawyer101
I am interested in the other⁠ options you mentioned.
Do you provide services for a Seychelles nominee? If so, please DM.⁤

1) What is the maximum number of companies in which the nominee is listed /⁣ active?

2) What minimum salary should be paid (if necessary)?

3) Can the nominee be⁢ based outside of Seychelles?

4) How often should board meetings take place (if necessary)?

Ευχαριστώ πολύ

 

[EliasIT]

It doesn’t matter at all how you manage a Seychelles company from abroad, and you‌ can actually structure it however you like; there aren’t really any authorities that take an‍ interest in it.