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Permanent Establishment rules UAE, with new CT on Companies

There must be something i'm missing.
Why do you guys think that UAE will not enforce a law that is preventing people to operate shell companies from UAE?

Because everybody would leave and UAE wants people to stay.

I mean, why you guys don't operate directly with a freezone company?

Depends on what you do, but not everybody operates through their FZCO.

Is it because UAE banks suck?

Not really, some like ENBD are quality banks.

Is it because of problems with payment processors or clients not trusting a UAE entity?

Both are correct. Again depends on what you do.


Theres a lot of countries on Earth with laws and rules on paper and thats nice and all but then you go there and reality is a completely different story. Not everywhere is like Germany/Sweden for example.
 
Look i understand that but honestly, where would people go if they really will start cracking down on people managing offshore companies from UAE?

tbh no idea but Qatar maybe?

What im trying to say is that Emirates is making big efforts into making people stay at the family level. They wanna break the years long trend of people going there for a few years to then go back to their home country.

At the end of the day its a soulless place in the middle of the desert, tons of fun yeah but not the type of place most people look to relocate initially so if they start screwing the tax incentives... why be there?
 
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I am talking about Admob revenue income (similar to Adsense) which is considered as service income.

The only answer that comes to mind is that AdMob operates in a different way than AdSense and that's why they are paying you with royalties.

if they start screwing the tax incentives... why be there?

Because even paying 9% it's still a better place than Malta (for example) where you would pay 5% but you will live in an overcrowded polluted hell or some Caribbean island / secluded LATAM country where your brain will shrink because the only thoughts going through the mind of locals is how to get food, beer and sex (not necessarily in that order).
 
@hireblade89 Please dont make off topic posts. Start a new thread if you want to talk about your adsense stuff.

P.S I am deleting your posts.
 
Because even paying 9% it's still a better place than Malta (for example) where you would pay 5% but you will live in an overcrowded polluted hell or some Caribbean island / secluded LATAM country where your brain will shrink because the only thoughts going through the mind of locals is how to get food, beer and sex (not necessarily in that order).

True but again idt it will happen.
Time will tell i guess.
 
Ok so even if you are the manager of the LLC you suggest you can manage it from UAE and probably no one will bother you with the new 9% corporate tax, even if the foreign company is managed from UAE and in theory subject to the new tax. I thought the same, but better be safe than sorry.
Yes. they will not target you as this will simply means UAE's death as a business heaven.
If they will go after all the LLCs managed from UAE probably most expats will fly away from UAE in a matter of months.
Correct.
There must be something i'm missing.

Why do you guys think that UAE will not enforce a law that is preventing people to operate shell companies from UAE?
people will flee.
I mean, why you guys don't operate directly with a freezone company?

Is it because UAE banks suck?

Is it because of problems with payment processors or clients not trusting a UAE entity?
it's a mix of the above and plus other reasons.
UAE companies are expensive, that's the reality, so if your turnover isn't high enough, it doesn't make any financial sense to operate from a FZCO.
Also, it's not every one's cup of tea and some financial institution's won't do business with UAE based companies thanks' to FATF grey list.
and some clients specially in the US - and if your business is B2C - will absolutely refuse to deal with any middle eastern company.

Once Your average joe from southern Indiana sees a Dubai company mentioned in the footer of your store/website, he will only think "Muslims, dessert, 9/11, sharia law, brown guys" and he will absolutely go "america #1, muh freedum, muh guns, bla bla bla" and won't deal with you, I'm not saying that these actions are fair or correct, but this is just the reality that we live in.
and as other's mentioned, with a US LLC, your banking options are better "but only in the US and in USD", you will have better spreads, better banking opportunities, more opportunities to scale your business globally and much more.
Look i understand that but honestly, where would people go if they really will start cracking down on people managing offshore companies from UAE?
Honestly, no where, but to be objective, they will likely go to a territorial country or a country whom tax office doesn't give a flying f (Malaysia, Thailand...etc)
tbh no idea but Qatar maybe?
maybe, Qatar had a great opportunity to through themselves out there and tell the world what can they offer through the world cup. only time will tell if they utilize this exposure the right way.
What im trying to say is that Emirates is making big efforts into making people stay at the family level. They wanna break the years long trend of people going there for a few years to then go back to their home country.
Correct. and Russians elites and their families are already making good use of this trend. some higher ups like it, others don't want the UAE to be a playground for a certain group, they want to maintain a neutral stance with everybody. and be the "USA" of the middle east in terms of cultural diversification.
At the end of the day its a soulless place in the middle of the desert, tons of fun yeah but not the type of place most people look to relocate initially so if they start screwing the tax incentives... why be there?
that was the thing of the past, they want to become a futuristic, capitalist county with great opportunities for the right opportunists. So, make use of that and grow yourself and your business/es further.

UAE is here to stay, once they normalized their relation with Israel and money started flowing from UAE to Israel and viceversa, it was literally game over. Money talks and Israel has that much power over the US. Israelis don't want to jeopardize their relationship with the UAE and having to face the Iranians all alone. UAE played their cards right, whether you agree with these policies/their politics or not, that's a smart move. and both parties are hellbent to expand these relationships even further.
See the signs and make use of them. be an opportunist.
 
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it's a mix of the above and plus other reasons.
UAE companies are expensive, that's the reality, so if your turnover isn't high enough, it doesn't make any financial sense to operate from a FZCO.
Also, it's not every one's cup of tea and some financial institution's won't do business with UAE based companies thanks' to FATF grey list.
and some clients specially in the US - and if your business is B2C - will absolutely refuse to deal with any middle eastern company.

Once Your average joe from southern Indiana sees a Dubai company mentioned in the footer of your store/website, he will only think "Muslims, dessert, 9/11, sharia law, brown guys" and he will absolutely go "america #1, muh freedum, muh guns, bla bla bla" and won't deal with you, I'm not saying that these actions are fair or correct, but this is just the reality that we live in.
and as other's mentioned, with a US LLC, your banking options are better "but only in the US and in USD", you will have better spreads, better banking opportunities, more opportunities to scale your business globally and much more.

Fair enough but would you say that banking options would still be better if a US LLC is owned by a UAE resident (either natural or legal person) than operating a multicurrency account in UAE?

Will Mercury, Relayfi and all the usual suspects open you a bank account when they will hear that UBO is a UAE resident?

I guess since UAE is on the FATF list it is difficult / expensive to receive USD directly in UAE
 
Fair enough but would you say that banking options would still be better if a US LLC is owned by a UAE resident (either natural or legal person) than operating a multicurrency account in UAE?

imo it aint that US banks are 'better' per se. Its just that some people will see a SWIFT code from a bank in the Middle East and will just refuse to transact with you.

There're some very solid banks in UAE, but its a matter of perception.

If you dont deal with clients directly, UAE banks are fantastic.
 
Fair enough but would you say that banking options would still be better if a US LLC is owned by a UAE resident (either natural or legal person) than operating a multicurrency account in UAE?0
It's not about which one is "better", it's about how are you gonna use them.
US EMIs/banks serves you better when dealing in USD with US clients/services. for other purposes (e.g. investments) UAE banks are more than fine.
Will Mercury, Relayfi and all the usual suspects open you a bank account when they will hear that UBO is a UAE resident?
Yes. I've no problem opening with novel, mercury, brex..etc with My UAE residency.
I guess since UAE is on the FATF list it is difficult / expensive to receive USD directly in UAE
No, some banks have some delays, but your money is usually credited within 1-3 business days.
 
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Fair enough but would you say that banking options would still be better if a US LLC is owned by a UAE resident (either natural or legal person) than operating a multicurrency account in UAE?

Will Mercury, Relayfi and all the usual suspects open you a bank account when they will hear that UBO is a UAE resident?

I guess since UAE is on the FATF list it is difficult / expensive to receive USD directly in UAE
0 problems faced. It is really a breeze there.
Opening UAE business banks is like a magnitude harder as a Dubai resident.

You can use ACH in US (which is very easy for sending cash inside US, just 2 numbers needed and no cumbersome swift), some ecom options like shopify pay etc. You can setup Interactive brokers etc.

Usd wires are also easy to get. IB usually credits within hours on UAE banks and others need a day or two but that can happen even with Fedwire and sending inside US.
 
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Malaysia, Thailand, Philippines, Singapore and of course, the elephant in the room - the UAE.
you can easily scrap all the above methods and operate as usual and they will not bother you, you are not their main target nor the reason they implemented this tax. They won't go after you unless you are involved with shady business practices.
I agree on what MiddleEuroAsia states, they won't bother you and even some of them legally you don't have to pay any tax on your foreign income.

If you employ people or do business in those countries itself, I do recommend to fully comply with the part of business/income you derive in that country (by employing people or doing local business) and pay correctly all taxes as well don't let any outside money flows go through that local business.

In the PH you have no crs and 100pct bank secrecy where even the government or any instance by court order can't access your account balance / transactions unless you are a terrorist or child trafficker.

So if you are a resident in one of the SEA countries mentioned, be a resident there, live there most of the time and cut all ties with your citizenship country you are good.
 
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Fair enough but would you say that banking options would still be better if a US LLC is owned by a UAE resident (either natural or legal person) than operating a multicurrency account in UAE?

Will Mercury, Relayfi and all the usual suspects open you a bank account when they will hear that UBO is a UAE resident?

I guess since UAE is on the FATF list it is difficult / expensive to receive USD directly in UAE
From US "Banking" (Mercury, Relay etc.) point of view it doesn't make a difference according to what we have seen however some clients reporting they get input from US based CPA's that a FZCO as US LLC Shareholder can trigger C-CORP requirements.

Still - everyone seems to get away with it - even the guys with almost 100% US Sourced income from US clients are not facing any issues.

We as DLS Dubai recommend our clients having a FZCO setup with us - to form a disregarded passthrough single member US LLC with themselves as only company owner with Dubai Residence - to faciliate US payments from foreign Comapnies having just a US based bank account as well - famous example: Binance Account under FZCO makes deposits and withdrawals to the Binance entity based on the Seychelles holding a Signature US Bank Account. In this way it's impossible to trigger anything on the US side.

However meanwhile you have "Mercury like"finanical institutions onboarding directly the FZCO and clients with existing LLC's starting shifting over the whole payment processing directly to the FZCO while for the reputation they claim "XXX webiste - concept and design by XXX LLC - payment and collecting by XXX FZCO" works perfectly fine and got confirmed from several US based CPA's / Lawyers we are working with.

With this scheme the upcoming 9% CT are passed by and our clients are happy to remain 0% Tax even with heavy US business exposure.

Yes - the peanut counters are still not happy because the FZCO can't collect at the same % rate with payment gateways like the US LLC - however this is the cost of doing 0% Tax Offshore Business.
 
Form a FZCO with a good freezone authority, appoint yourself as a director of the FZCO, make the FZCO a holder of the US LLC, do your business via LLC (but make sure to have another director managing the US LLC, at least on paper) and then repatriate the profit later to the FZCO. Simple, 0 tax structure.

Hi @MiddleEuroAsia would that scheme work with a UK LLP instead of a US LLC? Basically me and my FZCO will be the shareholders of the UK LLP and in that way I would be able to get a business bank account in Europe and decent rates for payment processing. Stripe and PayPal are a total ripoff for businesses in the UAE and I already had a Greek client refusing to pay an invoice made by a company in an Arabic state as you mentioned.
 
Hi @MiddleEuroAsia would that scheme work with a UK LLP instead of a US LLC? Basically me and my FZCO will be the shareholders of the UK LLP and in that way I would be able to get a business bank account in Europe and decent rates for payment processing. Stripe and PayPal are a total ripoff for businesses in the UAE and I already had a Greek client refusing to pay an invoice made by a company in an Arabic state as you mentioned.

It would probably be a bit of a challenge to get a payment processor to accept such a setup.
Other than that I completely agree with @MiddleEuroAsia - he was way ahead of all this here.

But where do you find a manager you can trust? And in a jurisdiction that won't cause trouble with bank accounts?
 
Form a FZCO with a good freezone authority, appoint yourself as a director of the FZCO, make the FZCO a holder of the US LLC, do your business via LLC (but make sure to have another director managing the US LLC, at least on paper) and then repatriate the profit later to the FZCO. Simple, 0 tax structure.


With the new laws in UAE, even this set up would now incur 9% tax and accounting/auditing requirements, correct?

US LLC/UK LLP owner living in territorial taxation countries with no enforcement of PE would be ideal to avoid all the complexity of UAE taxation. Thailand I think is the easiest, with easy immigration (Elite Visa). I spent some time in Thailand and absolutely no one on Elite visa is asked to file taxes if not remitting money in the same year.

Of course, a lot depends on personal preferences. 9% tax isn't a lot esp with all the ways you can lower your taxes for the next few years. People have been discussing personal income tax in UAE down the road etc..so if long term tax optimization is what one is after, maybe look outside of UAE.
 

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