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I just had a call with a lawyer, and here’s the summary.

First, we need to check if there’s a DTT with the US for the country we’re considering.

Then, we have to look at the royalty tax rate in that country. You can check the details here: United States - Corporate - Withholding taxes. It should ideally be 0%.

Next, it’s important to choose the right country.

A UK LLP could work well, and Kyrgyzstan is an option too, but you’d have to go there in person to set up banking, and the reliability of the banking system is something to think about.

One key point my lawyer mentioned is the need to create substance in the country where the company is formed. This ensures no one accuses you of using the company purely for avoiding U.S. royalty taxes.

To do this, renting an office, hiring a local director, and paying them a salary are good steps to reduce any risks.

This approach makes it more solid and compliant.

The next problem is tax residency, probably I would have to sign W8BEN-E, and UK company should be a tax resident of the UK by default.
 
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First, we need to check if there’s a DTT with the US for the country we’re considering.

Then, we have to look at the royalty tax rate in that country. You can check the details here: United States - Corporate - Withholding taxes. It should ideally be 0%.
Yes, I always used this page. You not? UK LLP works but only if you spend out all money on fiverr to the final destination. If you setup as UK LLP tax transparent, I think the main problem is that if your company is not paying taxes there because not tax resident in UK, you technically do not fulfill the DTA requirements and are very likely subject to troubles. I think with Google more or less checking, it may slip through for a while, but certainly is not a stable situation.

The question is how you want to get the money? Like the fiverr guys that they need to pay personal tax elsewhere? Or you want to get it as dividends from a company (more flexible as more countries have no taxes on dividends than on personal income)?

Kyrgyzstan and Armenia may work, just need to make sure to fulfil the requirements of the free zones. Do you think we can claim that the income is from software development? I mean like programming websites which then make ad income?
 
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A UK LLP could work well

A UK LLP would not work because it's not tax resident in UK so you can't provide TIN to claim 0% WHT on US royalties.

Also you should familiarize yourself with the IRS limitation on benefits table.

You'll quickly discover that there are only a handful of places worldwide with 0% WHT on US royalties + no LOB clause in the treaty.
 
A UK LLP would not work because it's not tax resident in UK so you can't provide TIN to claim 0% WHT on US royalties.
Yes, that's what I was trying to say and thought.

Also you should familiarize yourself with the IRS limitation on benefits table.

You'll quickly discover that there are only a handful of places worldwide with 0% WHT on US royalties + no LOB clause in the treaty.
All CIS. But even if there are limits, you could actually meet them if the business is proper.

Ok, so back to the question. Can we do free zone somehow?
 

Leo Vanguard

 
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Anyway KG seems like a solid option, especially with the


I already see some YouTubers are residents there.

Do you have to pay in the tax on the distributed dividends ?
 
What would you do about this withholding tax on dividends in KG? How it's gonna work?
 

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What would you do about this withholding tax on dividends in KG? How it's gonna work?
Yes, like this:
@Marzio said it very well:
First thing first you should have a UAE holding company.

The only countries that have 0% WHT on dividends with UAE are:
- Kyrgyzstan 10% CIT
- Tajikistan 18% CIT
- Turkmenistan 8% CIT

But if you do HWNI, you get the royalties personally and they are exempt.


With Armenia, there are more options:
I think with this amount even an Armenia free zone could be possible. You can then transfer out the dividends through Singapore, maybe even through a private fund.
 
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Getting a PIN seems like an easy tasks, I'm just curious about the small details, like can you forward it, or exactly you must receive the package and sign it with the delivery guy, there are packages like that with the ups/dhl.
Who else should respond to that if not the provider you've used to establish your company? This thread doesn’t make any sense to me. And if your service provider can’t receive a package or letter for you, then you can find another one who will.
 
Who else should respond to that if not the provider you've used to establish your company? This thread doesn’t make any sense to me. And if your service provider can’t receive a package or letter for you, then you can find another one who will.
The question was just about hour they deliver the code. It is like Amazon. They write that they will send for a confirmation code by DHL where you need to be personally present and sign an oath while holding 8 forms of identification and a photo of their mother, while they actually and an email it a simple letter.

It was a legitimate question although entirely off-topic.

Let's stick to the topic. Who else has a lot of royalty that he needs to get without to much taken off?
 
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So, here’s how it works with Google:

You register a new AdSense account, receive a PIN code, and then confirm it on the AdSense website. After that, you submit the W-8BEN form if you applied as an individual, or the W-8BEN-E form if you applied as an entity.

From that point, Google stops withholding any taxes, and it’s your responsibility to handle taxes on royalties.