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Simple structure to pay minumum EU/US corp taxes for a non EU/US resident.

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May 26, 2020
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Hello folks,

Iam looking for simple structure to avoid paying corporate taxes when Iam not a EU/US resident.

Here are the options I have encountered:

a.) In US incorporate a Delaware or Wyoming LLC which doesnt tax income that is not originated from the US. If you have a taxable income from US citizens then make the company owners to the name of your friend, and keep yourself as a foreign provider of that company. Would these two work? Why do US companies that have clients all over the world prefer to incorporate in Netherlands though like Uber or AirBNB if their income from other parts of the world is not taxable?

b.) If you incorporate in the UK, then do the company to the name of your friend and you act as a foreign provider. The company will send the mayority of the profits this way and you are left with minumum to report as profit.

Anybody else know of other simple ways, or know of reasons these suggestions might not be a good idea?
 
To a: They get special tax agreements by the NL or irish governments. For example Uber BV has a 1% tax agreement. However it is far more complicated as they then deduct costs via RASIER and Uber Int. C.V in Bermuda. Would be hard for you to start a BEPS-Network like this.
To b: Don't get what you mean?!

If you are doing a remote business which does not need retail branches or real human work on US soil I would recommend you an EU company like a Malta IP Box (wouldn't go with the UK right now because of the uncertainties when leaving the EU if you want to do business within the EU). Then you do all the business via the Malta company and drag out profits to your US company with 0% corp tax. LLC needs to be single membered and disregarded so it is a tax through entity. Then the profits need to be declared on your personal income tax. Keep in mind that you still need to take care about the arms length principle when moving money from Malta to the US.
 
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