DIGITAL BUSINESS - What is the best corporate structure in our situation?

[Giuseppe Rossi]

Hello everybody

CURRENT SITUATION:
We are two partners living in two different countries and both benefit from the non-dom resident (UK and Malta), and would like to continue to benefit from it.


We have an online business in the sale of digital video courses and ebooks in Italian language, and consequently, 90% of our customers are in Italy (we sell through online adv, with no geographic target, but only linguistic. Customers speak Italian, but live all over the world.)

Currently, the sales volume generated is around € 2M per year.

Our business model is based on intellectual property (course content) owned by the company.
Everything else is just "adv" and "marketing" to promote these intellectual properties.

POTENTIAL SITUATION WITHIN 1/2 YEARS:
The partner living in Malta will leave Malta, and will likely move to the UK.

Therefore, the structure will also have to provide for the eventuality in which the 2 partners both reside in the UK, benefiting from non-dom.


QUESTION 1:
What is the best corporate structure to have a 0% taxation (or the lowest possible), considering where we are resident, and considering that it is a totally online business?

For example, if we opened an LLC in Delaware, would it be legal to manage the business even if we live in our respective countries (UK and Malta)?
Or in the second situation, both in the UK?

QUESTION 2:
Our company wants to use collaborators, and possibly hire people in smart working.
We are not interested in having offices, and we all work from home.
We focus on people's skills and not where they live.
Is it possible to hire people in a different country? If so, when does it become a permanent establishment? Does it have something to do with numbers of people (or percentage) hired in a specific country?


Thanks everyone for the answers

 

[Fred]

For your turnover I can recommend you the Dubai Company Formation.

It's 0% tax, offers high privacy without public company registrar and is non-CRS setup as the company formation grants you the residence visa we use to setup the local bank accounts. So there is nothing causing a conflict with your current non-dom status.

Don't forget that US LLC doesn't grant you any residence therefore is banking very limited to EMI like TransferWise that isn't recommended for such turnovers.

 

[Fulton Abraham Sanchez]

Hello everybody

CURRENT SITUATION:
We are two partners living in two different countries and both benefit from the non-dom resident (UK and Malta), and would like to continue to benefit from it.


We have an online business in the sale of digital video courses and ebooks in Italian language, and consequently, 90% of our customers are in Italy (we sell through online adv, with no geographic target, but only linguistic. Customers speak Italian, but live all over the world.)

Currently, the sales volume generated is around € 2M per year.

Our business model is based on intellectual property (course content) owned by the company.
Everything else is just "adv" and "marketing" to promote these intellectual properties.

POTENTIAL SITUATION WITHIN 1/2 YEARS:
The partner living in Malta will leave Malta, and will likely move to the UK.

Therefore, the structure will also have to provide for the eventuality in which the 2 partners both reside in the UK, benefiting from non-dom.


QUESTION 1:
What is the best corporate structure to have a 0% taxation (or the lowest possible), considering where we are resident, and considering that it is a totally online business?

For example, if we opened an LLC in Delaware, would it be legal to manage the business even if we live in our respective countries (UK and Malta)?
Or in the second situation, both in the UK?

QUESTION 2:
Our company wants to use collaborators, and possibly hire people in smart working.
We are not interested in having offices, and we all work from home.
We focus on people's skills and not where they live.
Is it possible to hire people in a different country? If so, when does it become a permanent establishment? Does it have something to do with numbers of people (or percentage) hired in a specific country?


Thanks everyone for the answers

G, hi. Wyoming or Delaware is an option to open an LLC combined with a Puerto Rico bank account, one that does not require to be present to open.

 

[Giuseppe Rossi]

G, hi. Wyoming or Delaware is an option to open an LLC combined with a Puerto Rico bank account, one that does not require to be present to open.

I have some questions:

1. For the opening the LLC, is it okay to use services like Stripe Atlas or Firstbase?

2. After opening the LLC, what should I do annually? Have an accountant in Delware?

 

[Roamer]

For example, if we opened an LLC in Delaware, would it be legal to manage the business even if we live in our respective countries (UK and Malta)?
Or in the second situation, both in the UK?

If you are both in the UK and managing the company from the UK, your company –regardless where it is registered – would be tax resident in the UK, and therefore pay taxes in the UK. Read about "corporate tax resident" and "central management and control".

 

[Fulton Abraham Sanchez]

I have some questions:

1. For the opening the LLC, is it okay to use services like Stripe Atlas or Firstbase?

2. After opening the LLC, what should I do annually? Have an accountant in Delware

G hi, The accountant can be in Delaware or any other U.S state.