I am looking for suggestions to take advantage of the zero withholding on royalties with certain countries due to tax treaties. With the US, one such locale is the UK -another is New Zealand, Trinidad and Tobago, the Netherlands, etc. What I'd like to do is set up an LLC or a trust (it's unclear to me whether a trust would benefit from the tax treaty) in the UK or Cyprus (also the beneficiary of 0 withholding) and then have the company or trust located offshore from the UK or Cyprus in a jurisdiction where there would be no corporate tax on the proceeds. I have a Belize corp, so that could be a possible jurisdiction. Any suggestions on a structure? I am not a US resident, and I'm a Belizean citizen, so there are no US tax planning issues beyond the zero withholding one. The main issues I am unclear on are what jurisdiction I could have the company or trust domiciled in that would result in a low or zero tax situation in Cyprus. I'm pretty clear that Cyprus would face zero withholding in the US, and other than filing a W-8 and obtaining a TIN, would have no US obligations.
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