Georgia works well, indeed. However, to avoid a 5% dividend withholding tax, you probably need to set up a holding (e.g., in UAE,
Estonia).
Estonia would not work as they have a "subject to tax" rule similar to what Singapore has. Dividends paid out from the Estonian holding would be subject to 20% tax.
Also if you sell the company in Georgia, the profit would be subject to 20% tax in Estonia once you pay them out from the holding company.
Cyprus would be a better place for a holding company, or the UAE.
Other solutions that come to mind:
Cyprus with the 90-day foreign employment rule (if it works):
https://www.offshorecorptalk.com/th...ncome-for-cyprus-non-doms-90-days-rule.34665/
Cyprus with a local company:
12.5% corporate income tax, but you could use company expenses to reduce that further - I've heard that the tax authorities are very flexible in what they allow.
Some minimum tax/social security on dividends, otherwise no capital gains tax.
Estonia:
20% CIT only applicable to dividends. Strong tax treaty network.
Rent a cheap apartment and declare tax residency in Estonia. Live as a nomad. As long as you don't stay more than 183 days in another country or have an apartment there, Estonia's tax treaties should give you good protection. Good reputation - unlike Cyprus, Estonia wouldn't immediately raise questions for tax authorities in other countries.
You can save your money in the company and invest it tax free. Use company expenses to pay for most of your life. Say you need 100k for personal expenses - that would cost you 25k in taxes per year.
If you make 1M in profits per year, that's only 2.5% effective tax and you can travel freely in the Schengen zone (no passport checks within Schengen, unlike with e.g. Cyprus).
UAE with offshore company:
Use an offshore company with some substance abroad. Could be a US LLC with a manager in a territorial tax country. Someone mentioned the Philippines would be a good fit for this (and salaries in the Philippines are very low). Pay out dividends to yourself. Even transparent entities like US LLCs are only taxed in the UAE if there is a PE - and enforcement will be very weak for years to come. There's no requirement to declare anything in the UAE if there is no PE. With a manager outside the UAE, you can explain there's no PE in the UAE. That would be substantiated further if you don't have UAE clients and don't spend a lot of time in the UAE.
Or just use the above mentioned Georgian VZ company - Georgia has no WHT on dividends paid out to the UAE.
If you can't get a UAE Golden Visa (there are many ways to obtain one), you would still need a company for the visa. But that shouldn't be an issue, just invoice your offshore company for 100k per year, so you stay below the CIT threshold. That would even lower the risk of a UAE PE further. Or use the UAE for a holding company (since holding companies don't have to pay corporate income tax).
Portugal NHR with a company in Cyprus or Malta:
Low corporate income tax, no tax on dividends in Portugal. But there is some risk of a taxable PE in Portugal. However, so far, enforcement is weak. But there's always a risk that this could change.
@Martin Everson Do you have a bit more info about Kazakhstan?
How easy is it to find good developers in Georgia or Kazakhstan? What are typical salary ranges there?
What would be typical setup and running costs of such a company?
