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Decided to open US LLC.
Anyway I have to pay in Georgia, as all the job is done from Georgia.
hold on.

What if somebody gets a HNWI Georgian residency with georgian tax certificate and does the work from outside georgia? (for example UAE).

Let's imagine another EU country is challenging your residence, based on Georgia-EU country treaty most probably a tie breaking rule will be a permanent home.

You can have an apartment rented in Georgia for 100usd/month so you have tax residence certificate from GE and qualify also under the DTA. At that point the US LLC distribution will be considered as foreign income according to the georgian tax code.

Any comment is appreciated.
 
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hold on.

What if somebody gets a HNWI Georgian residency with georgian tax certificate and does the work from outside georgia? (for example UAE).

Let's imagine another EU country is challenging your residence, based on Georgia-EU country treaty most probably a tie breaking rule will be a permanent home.

You can have an apartment rented in Georgia for 100usd/month so you have tax residence certificate from GE and qualify also under the DTA. At that point the US LLC distribution will be considered as foreign income according to the georgian tax code.

Any comment is appreciated.
They also use cfc rules, most of europe uses. Meaning the company would have to be controlled by the director from the country where it is incorporated or would just handled like Georgien company tax wise.
 
They also use cfc rules, most of europe uses. Meaning the company would have to be controlled by the director from the country where it is incorporated or would just handled like Georgien company tax wise.
this seems more a matter of residence of the company (Place of Effective Management criteria).
i believe you are mixing 3 concepts
1) residence of the company (based on internal legislation and on DTAs)
2) presence of permanent establishment (again internal legislation and specific DTA)
3) CFC which concerns usually a passive income company that becomes disregarded for tax purposes in the owner's taxable base

as far as i know, georgia has no CFC legislation in place. While other points 1) and 2) require a case by case analysis
 
this seems more a matter of residence of the company (Place of Effective Management criteria).

i believe you are mixing 3 concepts
1) residence of the company (based on internal legislation and on DTAs)
2) presence of permanent establishment (again internal legislation and specific DTA)
3) CFC which concerns usually a passive income company that becomes disregarded for tax purposes in the owner's taxable base

as far as i know, georgia has no CFC legislation in place. While other points 1) and 2) require a case by case analysis
There is a German Youtuber that moved there and got a real Tax Accountant involved that said, they have basically have the same regulation there they just call it different.