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US LLC and tax treaty

Parabola

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Jan 24, 2021
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Hi guys,

I have a plan to set up a US LLC. I have a Croatian and Serbian citizenship, but mainly reside in Serbia. Still, I travel a lot because of my job and I am on travel between 4 and 8 months during a year. Croatia is on the way to have a tax treaty with USA, but its still unknown when its going to happen, should be soon as I heard.

Lets imagine now that Croatia has a tax treaty with US at this moment. If I am an owner of US LLC and I set up a company in Croatia, should I be an owner of both companies or should I make my brother owner of a Croatian company (he is citizen and resident of Croatia) ? Ofc I am asking from tax perspective. Remember, I am not living in Croatia, mainly in Serbia, but even there not that much because I travel a lot.

The main plan is to transfer all of the profits from US LLC to Croatian company. So, no taking dividends from US LLC, no credits, nothing. The goal is one and only, to transfer profits to Croatian company, with as low taxes paid as possible. I would go from Serbia to Croatia to take the money if needed.

So what would be the best set up for this idea? If I stay longer in Serbia, would it interupt my plans?

Cheers.