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Structure advice for SaaS Brazil and Panama Resident

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May 2, 2023
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Greetings, need your best advice for this case scenario:

Brazil resident with Brazil company, working with SaaS, also Panama permanent residency.

Need to declare ownership of company in Brazil but need legal tax free for this.

My idea is: UK Holding owning Panama IBC where I would only be resident Director. Panama IBC would own US LLC - US LLC for payments processing (Stripe etc) - Panama IBC to receive eventual Dividends/Profits from US LLC - UK Holding maybe receive some dividends from Panama.

Would declare in BRazil ownership of UK Holding and nothing else because don't need to receive money in Brazil.

Would this be a safe structure? Pros and Cons? What do you suggest as changes/alternatives?

Thanks :)
 
Panama IBC would own US LLC
This is a bad idea due to branch profits tax.

What I would do in your case is combine some kind of foreign entity (IBC/LLC or LP/LLP) with banking in the US or Puerto Rico. Then take out the dividends/distributions as crypto and spend it in Brazil.

If you want to stay legal, corp tax in Brazil is 15%. Check if there are any R&D exemptions available in regards to software development.
 
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