Best countries to incorporate for Google Adsense

[yngmind]

What would be the best countries to incorporate for Google Adsense income?

It's a royalty income, and the US charges 30% WTH tax, so the country should have DTT with the US and have somewhat no taxes.

I think it's Georgia and Armenia.

 

[daniels27]

Yes, we had this discussion a couple ot times:

Post in thread 'Best country to incorporate for YouTube?'

Jun 13, 2024

I'm thinking of starting some youtube channels.

You are putting cart before the horses because optimizing for zero income doesn't make sense and you'll shortly understand why.

Any suggestions where I could/should form a company that has a US tax treaty, and minimal tax

Just for the sake of conversation to identify the right country you need to identify a country that has zero / minimum WHT on US royalties with no LOB, low CIT AND zero / minum WHT on dividends to your tax residency country

To this date you have few options:

1. Georgia: 0% WHT...

• Marzio

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Or this one, if you want to live there:

Post in thread 'LLC for US amazon biz, UK citizen'

Dec 4, 2023

Awesome! Can you recommend any Georgia companies that offer these services?

Wait, territorial taxation in Georgia is only for natural persons, not companies.

This means that to achieve what i said you have to get Georgian tax residency.

• Marzio

• 

 

[Marzio]

I couldn't have said it better

 

[yngmind]

What about having a US LLC and being a tax resident in the UAE? I think I will be charged 30% in that case.

 

[daniels27]

What about having a US LLC and being a tax resident in the UAE? I think I will be charged 30% in that case.

The US LLC if tax-transparent is like not having it. If not tax-transparent, you pay profit tax and then withholding tax on dividends.

 

[yngmind]

Yeah, I've read some comments on Telegram, so basically, if you can't provide proof of tax residency in Georgia, they will charge you 30% tax.

What do you think about Armenia?

 

[daniels27]

Yeah, I've read some comments on Telegram, so basically, if you can't provide proof of tax residency in Georgia, they will charge you 30% tax.

Yes, basically. But even then if you give them something fake, IRS may still investigate and then IRS will charge you back throug the payer.

But if they have been paid, you should be able to claim them back from IRS filing the appropriate forms.

What do you think about Armenia?

It is a very good country and also among those without WHT:
https://taxsummaries.pwc.com/united-states/corporate/withholding-taxes
I think the main reason Georgia is discussed here so often is because it is the only country with 0% WHT which does not tax foreign income of individuals.

If you go the way with a company, there are others you can check too Azerbaijan, Belarus, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan. Maybe a company in Pridnestrovie with registration in Moldova would do it too?

Turkmenistan with 8% would be an option.
Kyrgyzstan with 10% would be an optoin.
Barbados with 5% WHT + 5%5% CIT up to 0.5M USD

I think Cyprus may also be an option with 0% WHT. There are some others with 0% WHT, if the amount is low, you may be able to open a company in a country with generous deductions etc. to fall below the taxation threshold. Or you just claim all your first class flights in that company too.

 

[yngmind]

You need to read the double taxation agreements!


Yes, basically. But even then if you give them something fake, IRS may still investigate and then IRS will charge you back throug the payer.

But if they have been paid, you should be able to claim them back from IRS filing the appropriate forms.


It is a very good country and also among those without WHT:
https://taxsummaries.pwc.com/united-states/corporate/withholding-taxes
I think it is not that often discussed here as taxes are higher than in the other CIS countries?

There are some schemes where you can pay literally no tax legally.

 

[daniels27]

There are some schemes where you can pay literally no tax legally.

Yes, they always exist. You just need to look out for them. I think Cyprus or Georgia should work quite well. There was a couple that was living tax-free on the girl's $3M royalties in Georgia:

Thread 'Critique My Lean US - Mauritius Structure (2.1% Effective Tax Rate)'

Sep 20, 2024

Good day Gentleman.

After wrestling with a UAE freezone/US LLC setup that turned into a compliance and AML audit nightmare (9% UAE tax, anyone?), and after spending some time in Georgia before realizing the political vibes weren’t for us (Hello Putin...), we’ve finally think we have found our sweet spot in Mauritius.

Why Mauritius?

Two words: tax perks and lifestyle.

It's by far the best run island I've ever been to - seems to have the chilled beach life when you want it, futuristic infrastructure in the built up areas as well as some high-end, modern villas with epic...

• Leo Vanguard
• Replies: 31
• Forum: Offshore Company

• 
• 

No any taxes paid, but they did not like the ploitical vibes. (They could just have gone to the country side or taken the expres bus to Armenia over the weekend.

 

[Houdini]

The US LLC if tax-transparent is like not having it. If not tax-transparent, you pay profit tax and then withholding tax on dividends.

True, has been discussed a lot of times.

 

[Marzio]

If you go the way with a company, there are others you can check too Azerbaijan, Belarus, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, and Uzbekistan. Maybe a company in Pridnestrovie with registration in Moldova would do it too?

Those are not options unless you structure things properly.

First thing first you should have a UAE holding company.

The only countries that have 0% WHT on dividends with UAE are:
- Kyrgyzstan 10% CIT
- Tajikistan 18% CIT
- Turkmenistan 8% CIT

The most interesting option is Kyrgyzstan's high technology park with 0% tax on profits and 0% WHT on dividens to UAE.

Problem: you need to meet the requirements of the tax code of Kyrgyzstan and hire people.

Another company option would be forming a Georgian international company that's taxed 5% CIT and 0% WHT on dividends.

Again, you have to satisfy their requirements and hire somebody in Georgia.

Bottom line: the easiest way is to obtain Georgian tax residency by staying 183 days and receive royalties tax free.

Any ther way require capital investments that imho should only be approached when starting to see some revenue to make sense of the investment.

 

[daniels27]

Those are not options unless you structure things properly.

First thing first you should have a UAE holding company.

The only countries that have 0% WHT on dividends with UAE are:
- Kyrgyzstan 10% CIT
- Tajikistan 18% CIT
- Turkmenistan 8% CIT

The most interesting option is Kyrgyzstan's high technology park with 0% tax on profits and 0% WHT on dividens to UAE.

Problem: you need to meet the requirements of the tax code of Kyrgyzstan and hire people.

Another company option would be forming a Georgian international company that's taxed 5% CIT and 0% WHT on dividends.

Again, you have to satisfy their requirements and hire somebody in Georgia.

Bottom line: the easiest way is to obtain Georgian tax residency by staying 183 days and receive royalties tax free.

Any ther way require capital investments that imho should only be approached when starting to see some revenue to make sense of the investment.

Ok, thanks. But if doing Kyrgyzstan with UAE, can you do this in UAE free zone or how to prevent taxation there?

 

[yngmind]

The solution is to find a Georgian friend and use him as a nominee. He will be a Georgian tax resident, so his taxes will be minimal. Then, he will just buy crypto and send it to you. It will be a black hat scheme.

The legal one would be just hiring a Georgian director and paying him a salary.

 

[JohnLocke]

The solution is to find a Georgian friend and use him as a nominee. He will be a Georgian tax resident, so his taxes will be minimal. Then, he will just buy crypto and send it to you. It will be a black hat scheme.

The legal one would be just hiring a Georgian director and paying him a salary.

How did you get to this, I mean you just answered your own initial post?

 

[yngmind]

How did you get to this, I mean you just answered your own initial post?

My mind can easily create such schemes after spending 4 years on OCT.

 

[Marzio]

Ok, thanks. But if doing Kyrgyzstan with UAE, can you do this in UAE free zone or how to prevent taxation there?

AFAIK an UAE company that receives dividends from non resident subsidiaries is exempt from UAE CIT (if participation exemption requirements are met).

The solution is to find a Georgian friend and use him as a nominee. He will be a Georgian tax resident, so his taxes will be minimal.

Well good luck finding somebody that will buy into your scheme and that will not cost you more than a white hat solution because if he is going to help you he surely wouldn't do it for little money (unless is desperate or stupid or wants to screw you)

The legal one would be just hiring a Georgian director and paying him a salary.

Georgian director...of what? If for a US LLC you are immediatly making the US LLC tax resident in Georgia and liable to 15% CIT upon distribution.

 

[yngmind]

Georgian director...of what? If for a US LLC you are immediatly making the US LLC tax resident in Georgia and liable to 15% CIT upon distribution.

Of Georgian company

• Dividends paid by a Free Industrial Zone (FIZ) entity: Exempt (0%)
• Dividends paid by an entity with International Company Status (ICS): Exempt (0%)

CIT for Virtual Zone Companies OR Free Industrial Zone (FIZ) entity: Exempt (0%)

CIT for International Company Status: 5% at the time of distribution.

 

[daniels27]

Of Georgian company

I think we discussed this once, see my first post. It won't work as you cannot get the tax exemption for the dividends.

You can only pay a individual resident.

 

[daniels27]

AFAIK an UAE company that receives dividends from non resident subsidiaries is exempt from UAE CIT (if participation exemption requirements are met).

Ok, then we finally have the gold solution. Kyrgistan company owned by UAE holding. Is it that easy?

 

[Marzio]

CIT for Virtual Zone Companies OR Free Industrial Zone (FIZ) entity: Exempt (0%)

Forget abut VZC or FIZ entities, the former is strictly for software companies and AdSense will not cut it (unless you display AdAsense through an app you develop) and the latter is for industrial businesses.

Ok, then we finally have the gold solution. Kyrgistan company owned by UAE holding. Is it that easy?

I never found their list of requirements so i can't tell but surely you have to be REALLY motivated to form a company there, hire people and go through language barriers.