Tax residency in Georgia while living in 2 European countries?

[Mr Gus]

Would you be able to claim treaty benefits with the Georgia HNWI program regarding US withholding taxes on royalties?

Let's say you become a HNWI tax resident in Georgia but don't spend a single day of the year in Georgia but instead you live in a zero tax country, all work is performed from the zero tax country and your income is subject to withholding taxes in the US. Would you be able to claim US treaty benefits as a HWNI in Georgia in this case? Since the work is not performed in Georgia I assume it's not taxed in Georgia and views as foreign sourced income.

In the DTT between the USSR/US, which the US deems applicable to Georgia as well(except Georgia doesn't recognize it), I haven't found any exceptions in the DTT that could make you not be able to claim treaty benefits.

Anyone that has more knowledge about this?

 

[Marzio]

Georgia HNWI program was changed last year.

If you are willing to satisfy the requirements then i guess you could claim treaty benefits since there's no LOB clause in the old USSR-USA treaty so a Georgian tax ID would get the job done.

I would be cautious in depositing $500K in a Georgian bank tho.

 

[Don]

I would be cautious in depositing $500K in a Georgian bank tho.

These days lots of businesses are doing so to buy assets in Russia at discount.

 

[jafo]

These days lots of businesses are doing so to buy assets in Russia at discount.

Really? Like what type...if you don't mind disclosing.

 

[clemens]

I would be cautious in depositing $500K in a Georgian bank tho.

Yeah, that is not the safest place at the moment.

 

[Don]

Really? Like what type...if you don't mind disclosing.

Try buying anything (properties, companies) from a russian resident, most EU banks would go apeshit. Smart people use foreign banks or even currencies.

 

[jafo]

Try buying anything (properties, companies) from a russian resident, most EU banks would go apeshit. Smart people use foreign banks or even currencies.

I wasn't clear...

These days lots of businesses are doing so to buy assets in Russia at discount.

What type of assets are businesses buying in Russia at a discount?

PS. If you don't mind disclosing...

 

[Don]

I wasn't clear...

What type of assets are businesses buying in Russia at a discount?

PS. If you don't mind disclosing...

Companies (not a secret, simply google to find more info)

Russia: Foreign companies forced to sell assets at bigger discounts to get govt's approval to exit country, according to Reuters sources - Business & Human Rights Resource Centre

www.business-humanrights.org

Putin Signs Secret Decree to Buy Discounted Western Companies – FT - The Moscow Times

President Vladimir Putin has signed a confidential decree giving the Russian government powers to buy Western companies at a “significant discount,” the Financial Times reported Thursday, a move likely to make it harder for them to exit the country.

www.themoscowtimes.com

Russians bought $40B Western assets at big discount: report

New regulations make it harder for foreign firms to leave Russia, and force firms trying to leave to sell their operations at a large discount.

www.businessinsider.com

 

[jafo]

Companies (not a secret, simply google to find more info)

Russia: Foreign companies forced to sell assets at bigger discounts to get govt's approval to exit country, according to Reuters sources - Business & Human Rights Resource Centre

www.business-humanrights.org

Putin Signs Secret Decree to Buy Discounted Western Companies – FT - The Moscow Times

President Vladimir Putin has signed a confidential decree giving the Russian government powers to buy Western companies at a “significant discount,” the Financial Times reported Thursday, a move likely to make it harder for them to exit the country.

www.themoscowtimes.com

Russians bought $40B Western assets at big discount: report

New regulations make it harder for foreign firms to leave Russia, and force firms trying to leave to sell their operations at a large discount.

www.businessinsider.com

Nice! Thank you!

PS. I was dreaming of buying a PH in Moscow or St. Petersburg from a scared Westerner at a +50% discount

 

[JohnLocke]

Companies (not a secret, simply google to find more info)

Russia: Foreign companies forced to sell assets at bigger discounts to get govt's approval to exit country, according to Reuters sources - Business & Human Rights Resource Centre

www.business-humanrights.org

Putin Signs Secret Decree to Buy Discounted Western Companies – FT - The Moscow Times

President Vladimir Putin has signed a confidential decree giving the Russian government powers to buy Western companies at a “significant discount,” the Financial Times reported Thursday, a move likely to make it harder for them to exit the country.

www.themoscowtimes.com

Russians bought $40B Western assets at big discount: report

New regulations make it harder for foreign firms to leave Russia, and force firms trying to leave to sell their operations at a large discount.

www.businessinsider.com

If one doesn't deal with this on a daily basis, this is completely new knowledge. Thank you for the links.

 

[Revoltec]

Anyone on the ground in Georgia trying to go this route? Feel free to connect with me

 

[Benzouser]

Im in the same situation "move from Thai" also want to have atleast 180d in EU zone . . . but the thing is u have to register in the EU country u stay more then 90d in, and then IM gussing the tax agency will trigger some flag and wonders why u aint applying for tax ID "TIN" in that country.

Out if curiosity
If I'm in Spain 5.5 months
And Portugal 5.5 months
Which is allowed with EU passport (unless I miss something) and not registering with any beurocratic / governmental institute + not triggering any tax residency law

why / how exactly they will even think about
contacting me at all?

I'm curious to know how that works