US Withholding tax on royalties solutions
- Thread starter Mr Gus
- Start date
- Status
In the case of software at this point the best one is Cyprus using IP Box Regime to obtain 2.5% CIT
Apparently there is no way to obtain 0 % tax rate ,am I correct?
We can leverage a low taxation using some eastern europe countries but cannot achieve 0 % from what I understood from the discussion so far.
Apparently there is no way to obtain 0 % tax rate ,am I correct?
We can leverage a low taxation using some eastern europe countries but cannot achieve 0 % from what I understood from the discussion so far.
If you want to risk wouldn't be better using a US LLC with no public records and sign a W8BEN with your home country documents instead of a UK LLP ?
If you use a pass-through LLC and are not a US Person I do not understand how they could tax you.
I may have found another solution by moving to Portugal with the NHR program. I read that foreign royalties are not taxed. Since Adsense (as of June 2021) now count the money they pay you as royalties (in fact they apply the 30% WTH which is applied only to certain incomes like︀ royalties or dividends) moving to Portugal and receiving the money directly from there can be︁ seen by the Portuguese tax man as foreign royalties (you can even show them the︂ W8BEN you signed with IRS and that they consider it as royalties) and Portugal has︃ a tax-treaty with the US. Is this something that make sense?
I may have found another solution by moving to Portugal with the NHR program. I read that foreign royalties are not taxed. Since Adsense (as of June 2021) now count the money they pay you as royalties (in fact they apply the 30% WTH which is applied only to certain incomes like︀ royalties or dividends) moving to Portugal and receiving the money directly from there can be︁ seen by the Portuguese tax man as foreign royalties (you can even show them the︂ W8BEN you signed with IRS and that they consider it as royalties) and Portugal has︃ a tax-treaty with the US. Is this something that make sense?
I have not read above, if this has been mentioned, but the only country with no LOB provision in itas treaty with the US is Hungary. Hope this helps to the discussion
regarding USA withholding tax, tax residency of UBO & DTA
I put a lot︊ of useful Infos in this thread
https://www.offshorecorptalk.com/th...sdiction-for-collecting-adsense-income.34374/
I put a lot︊ of useful Infos in this thread
https://www.offshorecorptalk.com/th...sdiction-for-collecting-adsense-income.34374/
A Hungarian partnership would be a transparent vehicle for tax purposes and should not meet the tax residency for claiming benefits of the Treaty. Therefore if it is a partnership it cannot claim Treaty benefits
You say that a Hungarian limited partnership is regarded as an opqque entity for tax purposes in Hungary? If this is the case then maybe it would affect the interpretation of the treaty. Obviously, It has to be looked into the text and context of the treaty.
I am not just saying but you can also check that Hungary does not recognize the concept of flow-though entities. As a kind remark I think these type of advices should not be given by someone who is not intimately familiar with a country's tax system. Half-knowledge is dangerous
- Status