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RAK ICC withholding tax on US investments

Jbb1

Marketplace Seller
Oct 11, 2020
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Hello,

I’m considering opening an RAK ICC to hold some stocks and property.

I have a question regarding the US withholding tax. Is the tax based on the country of incorporation or the country where the UBO of the company is resident?

RAK ICC companies are specifically created to be offshore without any substance or links to the UAE so they are always tax resident in the country of the UBO.
 
Hello,

I’m considering opening an RAK ICC to hold some stocks and property.

I have a question regarding the US withholding tax. Is the tax based on the country of incorporation or the country where the UBO of the company is resident?

RAK ICC companies are specifically created to be offshore without any substance or links to the UAE so they are always tax resident in the country of the UBO.
You should register your RAK ICC with the local chambre of commerce in your country of residence and get a tax id number for it as well.
 
Hello,

I’m considering opening an RAK ICC to hold some stocks and property.

I have a question regarding the US withholding tax. Is the tax based on the country of incorporation or the country where the UBO of the company is resident?

RAK ICC companies are specifically created to be offshore without any substance or links to the UAE so they are always tax resident in the country of the UBO.
With UAE companies, normally, the non-treaty rate of 30% WHT should be applied unless you can get a tax residence certificate for the company, somewhere else.

RAK ICC stands for RAK International Corporate Centre. They provide multiple types of structures.

offshore company is RAK ICC IBC which is not eligible to apply for a Tax Residency Certificate in UAE, or trade in UAE.
Is this a requirement for withholding taxes?
Yes, in order to benefit from treaty rates you normally need a tax residence certificate.
 
Yes, you need to company to be tax resident in the country you want to treaty benefits to apply of course. A pass trough entity might be a better option if that is not what you are looking for.

What is your country of residence if I may ask.
Thailand, I have also thought about a UK LLP.

The main reason I’m looking for this setup is to avoid estate taxes.