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Recent content by rdevalex

  1. R

    UAE clarification of Freezone Qualifying Income

    It looks like something similar to Cyprus IP Box regime?
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    UAE clarification of Freezone Qualifying Income

    Consider the next setup: - US LLC develops and sells mobile apps on app stores and via Stripe. All development and product managment is outsourced to independent agents outside USA (outsoursing companies, freelancers), for example, to some company in Poland. - A single member of US LLC is UAE...
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    Tax residency in UK

    Understood. I just wanted to make sure that it doesn't matter how other countries treat US LLC - as a transparent or opaque entity. It looks like US LLC should always pay CIT in any country where a manager is taking decisions even though US LLC is teated as a transparent entity in that country.
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    Tax residency in UK

    What profit is liable to country's CIT where PE is triggered? Profit from all app sales or from app sales in that country? So, should US LLC pay CIT in this case despite such US LLC is treated as a transparent entity in a country where a manager taking decisions is a resident?
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    Tax residency in UK

    Do I understand correctly that a permanent establishment will be triggered due to a fixed place of management in that country? What taxes should pay such PE in that country, if all actual work (product management and development) is outsourced to some third country?
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    Tax residency in UK

    If a manager of a manager-managed US LLC is a resident of a country that treats a US LLC as a transparent entity, should such US LLC pay the corporate income tax in that country according to the "management and control" rules?
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    Tax residency in UK

    Consider the next structure: - I am non-dom UK resident and don't remit any funds to UK - I have a manager-managed US LLC that sells a mobile app on Google Play and on a website via Stripe - The manager of US LLC is UAE resident and he visits Bahrain 1-2 times per year to make strategic...
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    Tax residency in UK

    Yes, I have submitted W-8BEN-E form. I am pretty sure Google doesn't deduct US withholding tax from in-app purchases and subscriptions in Google Play. I just have found "Consolidated Withholding Tax Information Statement" report in Google Play console and I see deductions of the withholding tax...
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    Tax residency in UK

    It is true when you allow to unlock Premium features from the app itself. It is not allowed to redirect a user to your website to proceed with payment. You must use Google Play billing in this case. But if your Premum funcltionality is linked to user accounts, you can allow to unlock it on the...
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    Tax residency in UK

    Some update for my case. We have relocated to UK and have plans to stay here at least for 1-2 years. So, I am already a UK tax resident with the non-dom status. I still own UAE FZE company which sells an Android mobile application on Google Play (in-app purchases and subscriptions). This company...
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    Tax residency in UK

    Yes.
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    Tax residency in UK

    I have checked the financial reports in Google Play developer console and have not found any mentions regarding US Withholding tax but I see deductions for Brazil Withholding tax. Apart from UK corporate tax, will the dividends tax be also applied even with non-dom status and not remitting the...
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    Tax residency in UK

    Actually, I am not sure but I think I don't pay it. As I know, this tax is related to YouTube, AdSense, Google Play Books, but not Google Play developers. Also, I didn't find US in the list of countries for the withholding tax: https://support.google.com/googleplay/android-developer/answer/9384608
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    Tax residency in UK

    Yes, I know it. But it is better to pay 25% tax than 25% + 45% tax. This is why I am wondering if I should pay myself dividends or leave the profit in the company (and maybe invest it somehow) to be prepared for the worst scenario. Maybe in the future I will leave UK and will pay the dividends...
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    Tax residency in UK

    I am learning CFC rules to find out more details. I have found the next info: https://www.gov.uk/hmrc-internal-manuals/international-manual/intm194400 https://www.gov.uk/hmrc-internal-manuals/international-manual/intm194500 Do I understand correctly that I as an individual will not be a...