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Recent content by lifeisfun

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    UAE clarification of Freezone Qualifying Income

    Start writing a complete truth. Freezone company is not tax free if: - Company does not have a real office - Company does not have a real staff - More than half of decisions of director/directors is made outside of UAE - More than half of suppliers are from outside of UAE - Company is formed for...
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    UAE clarification of Freezone Qualifying Income

    We understand. You are advertising a charitable activity here. And of the hundreds of thousands of dollars a year you earn from it, you donate it all to charitable purposes and you have absolutely no reason to hide the truth that would ruin an activity from which you have nothing. Or would it...
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    Question UAE Freezone Company - Indian national/ Irish resident.

    This is not agains what I wrote. He want to apply for citizenship in a future. Only those years are counted towards limit, where he spends ar least 183 days per year. Person which spends 183 days per year in Ireland is taxed on a worldwide income. If he has no intent to stay in Ireland, he will...
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    UAE clarification of Freezone Qualifying Income

    US LLC which is considered to be a tax resident in UAE will be considered as a local partnership. Even almost no one uses it, this structure exists in UAE law. Partnership is tax transparent in the UAE. All profits will be considered as business profit of the sole proprietors. Even non licensed...
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    USA LLC owned by European resident = VAT or no ?

    DTT says that company in considered to be tax resident in a country of registration. And that if there exists PE based on a local law, profit which is attributable to this PE will be taxed on a local sourced profit there scheme. So company will be taxed in Spain just in spanish source profit...
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    USA LLC owned by European resident = VAT or no ?

    Here are so many missinformations.. He elected to have LLC taxed as C-Corp. What means that this LLC is not considered tax transparent any more. It is taxed as standard corporation. Based on DTT between USA and Spain, taxation of this company is as follows: All profits which source is in Spain...
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    UAE clarification of Freezone Qualifying Income

    The prohibition of retroactivity in law is part of the principle of predictability in any civilized country. Every civilized country has a ban on legal retroactivity enshrined in the basics of law (many even in the constitution). A country that announces tax regulations during the current tax...
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    UAE clarification of Freezone Qualifying Income

    That is not correct information. Singapore does not tax income which was not remmited to Singapore just in case if it was taxed in a country with which Singapore has DTT with tax rate at least 15.00 %. Singapore is not a tax heaven.
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    Tax residency with no or little or mimimum stay, ability to get tax certificate, No CFC Rules, territorial tax or taxfree

    That was the problem. If you have any taxable income (and you are a permanent resident), you can have a tax residency certificate very fast. It is OK to br employed in your own company with a minimum wage. And after having witheld 1-2 montly personal income taxes, you can apply for TRC and it is...
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    UAE clarification of Freezone Qualifying Income

    Fred will defend UAE as "the best solution for everything" as long as possible. His business is to sell IFZA freezone company formation service + visa. He is a main advertiser here. Even when freezone business will not make sense to the most of the business world any more, he will defend UAE for...
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    UAE clarification of Freezone Qualifying Income

    You are all still forgeting to one of main conditions. Only those freezone companies will be tax exempt which will have a real substance. It means: You need a real office You need a real staff (out of you as a director) The most of your suppliers have to be from UAE Allmost all decisions of the...
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    UAE clarification of Freezone Qualifying Income

    Transfer pricing is not applicable to salaries. OECD manual exactly says to which kind of transactions is transfer pricing applicable. Only problem with salaries is how you define a salary. There has to be at least some regular (monthly/weekly) amount paid + you can add bonuses (annualy or semi...
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    Tax residency with no or little or mimimum stay, ability to get tax certificate, No CFC Rules, territorial tax or taxfree

    Yes. Panama, Costa Rica. The only thing you can have in Paraguay based on residence permit is Tax ID. You have to spend 183 days per year + have a Paraguay as your vital interests centre to be able to obtain tax residency certificate. Even spending 183 days per year within country is not enough...
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    Question UAE Freezone Company - Indian national/ Irish resident.

    If you have a non dom status in Ireland, it means you are not spending 183 days per year in Ireland. Years in which you did not spend 183 days per year in Ireland will be not counted towards limit set for naturalization. If you spend 183 days per year in Ireland, you do not have a non dom status...