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    Belgium dividend withholding tax to UAE resident individual

    Definitely make sure you check this with a Belgian tax attorney first. Especially that Belgium recently went utterly haywire in terms of liquidation taxation for individuals, exit taxation for corporates and anti-avoidance. Your move to UAE isn't particularly notable. Nor is your willingness to...
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    tax solution for small business (30K profit)

    Thank you. I too am stunned by the incessant incorrect use of CFC and PE concepts... I humbly suggest that @Admin could introduce some sort of quiz on basic terms during signup :D .
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    Incorporating a cryptocurrency hedge fund in Singapore as a Thailand resident

    Sponsoring an employment pass and living in Singapore is an option, but you'd need to have a couple of year's salary and running costs on account balance first. By virtue of your living in Thailand, the Singapore Co. does not automatically become liable to tax or is not automatically tax...
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    CFC rules in Georgia

    You don't need an LLP if your LTD is not UK tax resident. Just saying. Tax domicile UK LTD. in Georgia and get Virtual Zone status (must check but should be possible)? Nomad worry-free (5% profit distribution tax) thereafter.
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    CFC rules in Georgia

    @khinkali There has to be a point where one just gives up. I think there's plenty of info remaining in this thread for those who bother reading into it ;).
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    CFC rules in Georgia

    Your attitude regarding the "Georgian tax man verifying something" is plain wrong. If there is any tax suspicion, the burden of proof is on you, buddy. 1) What does the definition of a generally accepted international taxation concept have to do with Georgia? If you can't figure this out, you...
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    CFC rules in Georgia

    Re: One month in Dubai - That is, unless, you are engaged by the Dubai client when in Georgia as a Georgian self-employed person.
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    Straw man secret bank account?

    Uh-oh. I see what's happening here. Meds. Don't forget to take them.
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    CFC rules in Georgia

    Correct, it mentions three months. I quote: 4. Notwithstanding the provisions of the first and second paragraphs of this article, a permanent establishment of a foreign enterprise in Georgia shall be the management of this enterprise by another person (another enterprise, subunit of this or of...
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    CFC rules in Georgia

    That is international taxation 101. Income is deemed sourced in the location where the actions leading to the generation of said income took place.
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    CRS Reporting, confused if I am reportable via my bank and broker.

    Well yes. However if you already have signs of special attention, at least now you have this card to play.
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    CRS Reporting, confused if I am reportable via my bank and broker.

    Yes, requesting information from a FI regarding reporting technicalities would be seen as a red flag for further analysis of account and possible AML reporting.
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    CRS Reporting, confused if I am reportable via my bank and broker.

    You can always make a GDPR request to find out what your tax man knows about you.
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    CFC rules in Georgia

    Dear @Poem the assumption in this thread was that the foreigner would rent a place in Georgia and, well, more or less live there. The question you raise is a complex one with much nuance in every specific case. I do not pretend to be an expert in Georgian law, and such finer things do...
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    CFC rules in Georgia

    Once again, more complicated than that. Consultation fees - look at the double tax treaty between GE and country you are consulting to. Most times, would be taxable in GE, however, if performed on location in excess of a certain number of months, may become taxable in client country instead...
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    CFC rules in Georgia

    @andrew28fl nomad bla bla . c o m are a cesspool of misinformation. As are a lot of offshore company peddlers in general. The whole subject is complicated and thousands of experts internationally have been working hard for going on two decades to close all international taxation loopholes whilst...
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    CFC rules in Georgia

    @Poem I am having trouble understanding what you're not getting. Can you help me by clarifying your question?
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    CFC rules in Georgia

    That is true. But then, the reality of the control of this entity should reflect this too. So either get a foreign trustee director (acting solely) or get 2/3 directors (you being 3) from a jurisdiction where you do not reside (and where you do not fear tax consequences). In the latter option as...
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    CFC rules in Georgia

    I quote from Page 9 here https://www2.deloitte.com/content/dam/Deloitte/ge/Documents/tax/Guide%20to%20Taxation%20and%20Investment%20in%20Georgia%202016.pdf : Permanent Establishment (PE) Pursuant to the Tax Code a permanent establishment of a foreign enterprise or non-resident individual in...
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