International Consulting Company: Where to set it up?

[singlelady90]

Hi
Lets suppose a team of 80+ people wants to put together a virtual consulting company under a trademark umbrella owned by one person. How would you structure the business to make sure the trademark owner (Which is also a consultant) can protect himself (assets protection) and save in taxes and liability? clients will be globally.

 

[JohnLocke]

Are you serious, is this a real question or just something that came to your mind?

 

[singlelady90]

Are you serious, is this a real question or just something that came to your mind?

What do you see so strange Admin?

 

[Jerry1911]

Which country is the majority of the team based in?

 

[singlelady90]

Which country is the majority of the team based in?

50% USA
10% Western EU
10% Singapore China Korea
10% UAE Saudi Arabia
10% Canada Australia UK
10% Russia Kazakhstan Ukraine

The trademark Owner lives in Germany, he does not want to incorporate in Germany. He is thinking about a Foundation 100% owner of an operative company, The foundation will pay him royalties for usage

 

[wheelspin]

CFC rules might kick in, German tax authorities aren't stupid. Honestly, it is not a prudential idea to operate from Germany with a foundation and some umbrella structures.

 

[singlelady90]

CFC rules might kick in, German tax authorities aren't stupid. Honestly, it is not a prudential idea to operate from Germany with a foundation and some umbrella structures.

What about having a operative company in Germany owned by the Foundation? In this way no matter what happen but the Foundation will cover all assets

 

[Jerry1911]

50% USA
10% Western EU
10% Singapore China Korea
10% UAE Saudi Arabia
10% Canada Australia UK
10% Russia Kazakhstan Ukraine

The trademark Owner lives in Germany, he does not want to incorporate in Germany. He is thinking about a Foundation 100% owner of an operative company, The foundation will pay him royalties for usage

I would set up the company in Dubai, leverage the team there for substance and hire everyone else as independent contractors.

@CaptK what are your thoughts on this?

 

[CaptK]

I would set up the company in Dubai, leverage the team there for substance and hire everyone else as independent contractors.

@CaptK what are your thoughts on this?

Yes that would be one option but you will be liable for VAT on UAE customers, and you couldn't use a Freezone for any GCC customer. It would have to be onshore.
Good thing it's plus VAT and UAE customers won't mind paying that. It does give you the headache of accounting which will cost you about $1k-$2K in the UAE.

Maybe Georgia or UK LLP could be another option.

If you have a good business case you can prove to the bank then a mix of UK LLP and UAE Freezone.

 

[singlelady90]

Yes that would be one option but you will be liable for VAT on UAE customers, and you couldn't use a Freezone for any GCC customer. It would have to be onshore.
Good thing it's plus VAT and UAE customers won't mind paying that. It does give you the headache of accounting which will cost you about $1k-$2K in the UAE.

Maybe Georgia or UK LLP could be another option.

If you have a good business case you can prove to the bank then a mix of UK LLP and UAE Freezone.

Guys

Thanks so much.

1. You are saying, as long as there is a substance (office) and some people, the company can be in any country. correct?
2. What about the Trademark owner (Private Person), can he give the right of usage to the company (Singapore or Dubai) and get back royalties to be taxed into his own country of residency?
3. If the local Director is also the Owner of the company Singapore and Dubai and also CEO of the EU Company do you think it can make a problem if the Holding company in in Singapore and Singapore is basically the one cashing in the profits????


Like:
- SINGAPORE or DUBAI: Owns Website
- Trademark: Owned by Private who give licence to SINGAPORE
- USA C Corp: Pay licence to Singapore
- Kazakhstan LTD: Pay licence to Singapore

How would you connect USA and KZ to SINGAPORE / DUBAI? By having the Holding in SG Dubai holding 51% Share or because of Piercing the Corp Veit it can be dangerous so it would be better to have an entity separated who just pay royalties to Sinagpore DUBAI?

 

[glengoolie]

the company will be taxed where it is being controlled from. office is irrelevant(with few country-specific exceptions).

that registered trademark is limited to the jurisdiction where it is registered. there is no such thing as global trademark. if the owner wants to license it, he must registered it in all countries/jurisdictions where the company wants to do business. also the trademark must match the categories in which the business will be done.

cyprus has good royalties tax laws(i think 80% is tax free?) but that will depend on where the owner of the trademark lives. he could set up a company to own and license the trademark but then you have to get the money out of that company and that involves taxes so there is no universal solution and it must be tailor-made to the said person.

ps: i think google runs everything from bahamas, just fyi

 

[singlelady90]

Panama company + panama bank account + merchant account

USA corp (no LLC) or (UK LTD+ nominees) with the same name as the Panama company that you will use for invoices and domain ownership

It's important not to invoicing customers from the same country where you have the "invocing " company

That way they are paying to a company in Panama but thinks you are in US / UK


Pay your team as freelances working for your Panama company

This is quite a genial solution.

Like Panama Foundation XYZ with Banking in Swiss

C-Corp XYZ send the invoice with the OBAN of the Foundation

Is this legal?Any issue?

 

[kkein]

We have been in the same situation and discussions.
The conclusion was that the umbrella company should be in the cheapest possible jurisdiction in terms of accounting.
The umbrella would then simply act as proxy for the final consultants and be never making profits (essentially proxy charging the client the same amount the cousultat charges the proxy).

In this way you would get quite a bit of accounting paperwork that needs to be sorted out cheaply, but no taxes as proxy makes no profit

 

[singlelady90]

We have been in the same situation and discussions.
The conclusion was that the umbrella company should be in the cheapest possible jurisdiction in terms of accounting.
The umbrella would then simply act as proxy for the final consultants and be never making profits (essentially proxy charging the client the same amount the cousultat charges the proxy).

In this way you would get quite a bit of accounting paperwork that needs to be sorted out cheaply, but no taxes as proxy makes no profit

Totally agree, what lawyers and Deilotte suggest:

1. Trademark Creator donate Trademark to Foundation Panama
2. Foundation establish a umbrella company (Panama as well $1500 + $700 Fees yearly)
3. Panama Umbrella company owns 51% share into 4x operative companies
4. 4x operative companies send under licensing agreement with umbrella companies the royalties to umbrella company bank account in switzerland
5. Beneficiary will pay taxes for whichever amount he wil withdraft to his residencyd country (if any)


Questions:

1. Can the Trademark Creator also incorporate his operative and pay royalties to umbrella company OR better to have Trademark Creator (Also Beneficiary of Foundation) receive royalties?
2. Do you think it is a problem if the bank account of the umbrella company is in a country who exchange (CRS) information? in other words, the place of residency of the Trademark Creator will know that the Foundations has $K on bank account and that he is the beneficiary.

What do you think about those points?

 

[mebuq]

can someone help me with my honkong company, can it own a Nevis company and both have bank accounts? where can I set up the Nevis company?

 

[JohnLocke]

can someone help me with my honkong company, can it own a Nevis company and both have bank accounts? where can I set up the Nevis company?

Please open a new thread either here or inside the mentor group gold which you have access too. What you are doing here is called hijacking others thread !

The conclusion was that the umbrella company should be in the cheapest possible jurisdiction in terms of accounting.

where would that be?

 

[kkein]

where would that be?

Idk, we didnt take it further. I would expect some place where the bureaucracy isn't over the top and the cost of labor is still low.. Bulgaria maybe?