UK Ltd, owner and director non resident - what options for bank accounts?

[Marzio]

Point to go for uk or cyprus for 0% withholding tax rate for motion pictures

If you are talking about 0% US withholding tax rate on motion pictures royalties there's bad news for you because both UK and Cyprus have a limitation on benefits article in their double tax treaty with USA that prevents what you are planning to do.

Briefly you will not be able to achieve 0% US WHT on motion pictures royalties if you are not a UK or CY tax resident.

How are you generating motion pictures royalties? Youtube? App?

 

[JustAnotherNomad]

There is nothing to hide.

Then why didn't you want to use a LT bank or EMI?

Point to go for uk or cyprus for 0% withholding tax rate for motion pictures.

That's not how it works.

Uk is more attractive with Wise, which gives good exchange rates - I spend 80% all in usd, that's quite important.

Wise doesn't onboard LT companies?

don't understand, not a specialist in this.

Yeah, it shows. Get some proper advice before you get yourself in trouble.

 

[Hmmm]

If you are talking about 0% US withholding tax rate on motion pictures royalties there's bad news for you because both UK and Cyprus have a limitation on benefits article in their double tax treaty with USA that prevents what you are planning to do.

Briefly you will not be able to achieve 0% US WHT on motion pictures royalties if you are not a UK or CY tax resident.

How are you generating motion pictures royalties? Youtube? App?

Youtube. But if company is uk tax resident, what's the problem? Only shareholder and director is non resident, but company pays taxes in UK.

Wise doesn't onboard LT companies?

Wise don't onboard from a lot of countries. I still in the waiting list for my Malta company for Wise and Revolut.

Or to establish the company with the assistance of GoSolo. The UK bank account is/was included in the package, even with the brick and mortar bank, IIRC.

GoSolo suspended onboarding new users.

 

[Marzio]

But if company is uk tax resident, what's the problem? Only shareholder and director is non resident, but company pays taxes in UK.

The company will pay UK taxes but that's not what bothers US.

They don't want people to avoid their withholding taxes because that's money lost for them so they were one of the first countries that included limitation on benefits clause in their double tax treaties.

So you correctly identified that UK and Cyprus have 0% US WHT on motion pictures royalties but you failed to read the details in their double tax treaties.

If you did you will know that to be able to claim treaty benefits AKA 0% withholding tax you need to satisfy certain requisites.

This for example is the UK-US double tax treaty, read carefully article 23.

 

[JustAnotherNomad]

If you're in LT, LT will regard it as tax resident under domestic rules. The company likely wouldn't even be tax resident in UK under the UK-LT tax treaty.
Please get qualified advice or you will get yourself in trouble.

 

[Marzio]

The company likely wouldn't even be tax resident in UK under the UK-LT tax treaty.

Unfortunately LT has 10% WHT on motion pictures royalties.

 

[Hmmm]

I think I don't know exactly how that WHT works, that's the main problem from which comes this idea about uk/cy companies.

I'm not sure if I correctly understood:
Let's say youtube project earned 100k, WHT rate 10%, WHT took 10k euro taxes in US.
Came financial year end, let's say company from various projects has 100k profit, in LT income tax is 15%, so 15k euro goes to taxes, but 10k I already paid in US, so in general left to pay only 5k?

 

[Marzio]

in LT income tax is 15%, so 15k euro goes to taxes, but 10k I already paid in US, so in general left to pay only 5k?

"A company may reduce tax payable on certain foreign-sourced income in Lithuania by taxes paid on that income in a foreign country if that Lithuanian company has received appropriate notice from that foreign country. The tax credit may not exceed the CIT rate payable in Lithuania."

Lithuania - Corporate - Tax credits and incentives

Detailed description of corporate tax credits and incentives in Lithuania

taxsummaries.pwc.com

 

[jafo]

I think about Wise, but not sure if they willing to open for UK company when director and shareholder is non UK resident, maybe someone know?

Not sure If I'm allowed to add a link to Twitter here, but search for Wise horror stories on Twitter and Facebook. They literally are robbing people. I have a lawyer friend in the UK and I had him look into Wise for me. His response after due diligence was: "You would be in better hands depositing your money into the hands of a random on the darkweb". Seriously, that is exactly what he said.

 

[lifeisfun]

Is Revolut Ltd acct, not a Revolut Bank acct usable with Stripe?

 

[JustAnotherNomad]

I think I don't know exactly how that WHT works

Then why don't you just start by talking to a LT acountant? That should be the first step.