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Is it legal to run USA LLC from Thailand on thia Elite visa ?

troubled soul

troubled soul

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Aug 23, 2020
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#1
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I read very confusing information online about running single person USA LLC from Thailand..
If you have Thai elite visa , Is it total legal to run USA LLC from Thailand ?
I am not looking for grey area or some bro science...
Is it legal in eye of Thai law to run USA LLC from Thailand using Thai elite visa ?
What is the best visa setup for running single person USA LLC for my digital business from Thailand ?

Thanks
 
#3
Marzio said:
Instead of opening countless threads asking about any structure imaginable why don't you simply ask "My business is XYZ and i don't want to pay taxes, what are my options?"
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Already did ...but could not get any useful practical answer....as you know I want to run Digital USA LLC business tax free......with Dubai seems very difficult as New corporate tax....and I do not want to play into grey area....and Bro science ....Trust me bro type of things....can you advice me any simple setup ?
 
#6
You didn't state your case so you can only expet to get general answers and waste time by going after any structure that you can think of.

Say "My business is [crypto trader, FBA seller, you name it], I want to pay [maximum amount of taxes you are wiling to pay] and i'd like to stay [desired country]." and i'm sure you'll get more useful answers
 
#7
Marzio said:
You didn't state your case so you can only expet to get general answers and waste time by going after any structure that you can think of.

Say "My business is [crypto trader, FBA seller, you name it], I want to pay [maximum amount of taxes you are wiling to pay] and i'd like to stay [desired country]." and i'm sure you'll get more useful answers
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Sorry for my mistake........
Next time I will be more careful ...
What will be your suggestion for this ?
My business is web developement , I want to pay zero tax.... and i'd like to stay Dubai ....
https://www.offshorecorptalk.com/th...evelopment-business-for-dubai-resident.41974/
 
#8
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#10
azb1 said:
noted...but I think I already mention single person USA LLC
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Sure, but that does not automatically let one deduct how your biz is really operated.
You could for example operate with another partner who gets the clients for you and you pay a % for these refs to him or whatever.

That being said, you are a one man shop doing web dev entirely on your own having like a handful of clients?
 
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#12
azb1 said:
I read very confusing information online about running single person USA LLC from Thailand..
If you have Thai elite visa , Is it total legal to run USA LLC from Thailand ?
I am not looking for grey area or some bro science...
Is it legal in eye of Thai law to run USA LLC from Thailand using Thai elite visa ?
What is the best visa setup for running single person USA LLC for my digital business from Thailand ?

Thanks
Click to expand...
Thailand is very simple.

You own a company overseas, it generates revenues, you receive a dividend, you wait till the next tax year, you can bring the funds in, tax free.

It's territorial based.

Running/Operating a company from Thailand doesn't follow some of the strict requirements like elsewhere whereby as you run from Thailand, the Thai Government deem it to be taxable within Thailand.
 
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#13
wellington said:
Thailand is very simple.

You own a company overseas, it generates revenues, you receive a dividend, you wait till the next tax year, you can bring the funds in, tax free.

It's territorial based.

Running/Operating a company from Thailand doesn't follow some of the strict requirements like elsewhere whereby as you run from Thailand, the Thai Government deem it to be taxable within Thailand.
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Mmh, US LLC doesn’t distribute dividends. Am I wrong ?
 
#14
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#15
SasuT said:
US LLC doesn’t distribute dividends. Am I wrong ?
Click to expand...

You are correct but we don't know how Thailand sees US LLCs

If Thailand sees US LLC as opaque then income is considered like dividends

If Thailand sees US LLC as transparent then income is considered like business profits

There are some countries that considers US LLC as opaque, for example UK and other that considers US LLC as trasparent like Cyprus.
 
#16
#17
I was only answering the question if US LLC distribute dividends :)

We all agree that managing US LLC from Thailand will create a PE but rest assured that some folks will manage their offoshore company from Thailand anyway relying on non enforcement.
 
#18
https://www.lorenz-partners.com/newsletter-no-70/Check Table 1

https://www.hlbthai.com/tax-implications-of-remote-working-in-thailand/#Permanentestablishments
https://www.hlbthai.com/double-tax-...ca-and-thailand-including-examples/#article-5
Let's say a Thai resident manages (online) his single-member US LLC that does business 100% outside of Thailand (no interaction with TH customers/providers/banks) from his either rented or owned personal accommodation.

From what I understand and according to US-TH DTA I don't see how he could trigger any "Asset PE", "Activity PE" nor "Agent PE"... Am I missing something?
 
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#19
Mercury said:
From what I understand and according to US-TH DTA I don't see how he could trigger any "Asset PE", "Activity PE" nor "Agent PE"... Am I missing something?
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Beside the fact that "home office" is akin to having an office, that he is providing servive from Thailand without working permit and that at some point he will ask his customers to buy his services you aren't missing anything.

At some point you guys need to be intellectually honest.

If you are the only one managing a company and the company isn't resident in the formation country, where do you expect to be tax resident? Nowhere?

C'mon.
 
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#20
Marzio said:
Beside the fact that "home office" is akin to having an office, that he is providing service from Thailand without working permit and that at some point he will ask his customers to buy his services you aren't missing anything.
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I agree with you regarding work permit although assessing what people are doing on their laptop at home (including determining home as place of management) is practically unenforceable. Of course, if you could get a work permit (implying properly structuring yourself with local company/substance) for remote work you are performing online then you will be taxed accordingly.

Marzio said:
If you are the only one managing a company and the company isn't resident in the formation country, where do you expect to be tax resident? Nowhere?
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Being consistent with the above: Not getting a work permit implies not working in Thailand implies no local source income.
Then, as long as this loophole still applies:
"If you are a tax resident of Thailand, foreign-sourced income, which includes business income from employment, rental income, interest, dividends, royalties, capital gains, etc., that is paid, brought in, or remitted into Thailand within the same calendar year would be subjected to Thai income tax."
 
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