US LLC or UK LTD + Malta or Portugal residency

[ilpablo]

Hi, I'm exploring these options.

Which one is the best combo?

I'm not just looking for the lowest possible taxation, but as well low cost of maintenance, less bureaucracy, and fewer headaches.

 

[Martin Everson]

Which one is the best combo?

For what i.e selling screwdrivers to native Americans?

 

[ilpablo]

For what i.e selling screwdrivers to native Americans?

Sorry I forgot to mention this.

Business: Digital Marketing Agency (clients mostly Americans, Canadians and Europeans) + Amazon Publishing + Fiverr + eventually e-commerce (also America and Europe + Canada + Australia)

 

[Martin Everson]

In terms of tax I am probably not best person to answer in regards to US clients and US LLC's run from Malta or Portugal. That complicates it things.

Perhaps someone else can offer input here?

 

[Marzio]

US LLC + NHR but only if you don't live full time in PT so that you don't create a PE in PT.

 

[jonathanv]

US LLC + NHR but only if you don't live full time in PT so that you don't create a PE in PT.

Is a PE dependent on the number of days living there or the number of days working there? I thought the NHR required 183 days in the country which matched the number of days for a PE.

NHR
"In order to avail of NHR status, you must stay for a minimum of 183 days in the country per year or maintain a property as your habitual residence."

PE
"Business activities derived from services, including consulting services, performed by an enterprise through its own staff or subcontractors hired with the purposes of carrying such activities in the Portuguese territory, provided that such activities are performed for a period or periods exceeding in the aggregate 183 days in any 12-month period starting or ending in the relevant tax year."

 

[Marzio]

I thought the NHR required 183 days in the country which matched the number of days for a PE.

You already know the answer

In order to avail of NHR status, you maintain a property as your habitual residence.

 

[ilpablo]

And what about just having a Maltese Self-Sufficient Residency + Maltese Company?

 

[Marzio]

And what about just having a Maltese Self-Sufficient Residency + Maltese Company?

In Malta you don't get away with "just" a maltese company.

To achieve 5% tax you need a trading company + holding company + usually fiduciaries.

If your business justifies that expense then go for it.

 

[ilpablo]

In Malta you don't get away with "just" a maltese company.

To achieve 5% tax you need a trading company + holding company + usually fiduciaries.

If your business justifies that expense then go for it.

Not at the moment, so what's the best easiest option instead?

 

[ciccino]

US LLC + NHR but only if you don't live full time in PT so that you don't create a PE in PT.

Hi, why do you think this is better than Malta + LLC?

I'm Italian as well, can you PM me?

 

[Marzio]

why do you think this is better than Malta + LLC?

Based on the latest informations we got, it's probably better for you to stay in Malta and investigate with @CyprusLawyer101 a resident non-domiciled company structure.