Hi Orange Kangaroo
I have a Limited Company in uk, that does software development. It needs to stay as it is, as it has a number of contract with existing customer.
I was thinking to create a Georgian 5% software company and become tax resident in Georgia
- Limited company in UK invoicing, let's say 100
- Georgian Software company that invoice to the UK, let's say 30 (arm's length principle) to the UK
So
- UK, profit 70 (on which it pays UK corporate tax). I can nominate local directors in UK to avoid estabilishing PE in georgia
- Georgian profit 30, it pays Georgian corporate tax (5%)
-
UK ltd pays dividend to me (70- uk CIT), individual tax resident in georgia. I think this should be tax exempt
- Georgian company pays dividend to me (30 - ge CIT) , individual tax resident in georgia. I think this should be tax exempt
Would this work?
Also, can you drop me a PM with the contact of your tax advisor, the fact that he understand what a PE is, is a good start.