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Gibraltar vs BVI

That makes sense, but I don't see that written anywhere on corporate residence in Singapore.
I once sent you the link in the old thread where you were angry at me and refusing to call Sovereign. Maybe this one
https://www.iras.gov.sg/taxes/corpo...ions-for-companies/taxable-non-taxable-income
How can a SG company use US PayPal?
Just open it. You need a US bank account. And an ITIN. There is a discussion on this in the other forum.
 
This is what I got from my service provider regarding offshoare taxation:

The term "offshore company" is not a recognized tax status under Singapore tax law.

For a company incorporated in Singapore, if the control and management of the company are exercised outside of Singapore, it may be considered a non-resident company for tax purposes. However, this does not automatically exempt the company from Singapore taxation on foreign-sourced income.

Foreign-sourced income is indeed not taxable if not remitted in Singapore. However, there is a difference between foreign income and foreign-sourced income.

Foreign income is income derived from outside Singapore while foreign-sourced income in accordance with IRAS (screenshot attached below) is foreign income that does not arise from a trade or business carried on in Singapore. To ascertain whether your foreign income is foreign-sourced income, we have to check the following:
  1. Is the agreement or contract for the sales made between the Singapore entity and the foreign client
  2. Is there a foreign branch or foreign subsidiary of the Singapore entity that contracted with the foreign client and provided the service from the foreign branch or foreign subsidiary

If the answer to either point 1 is "yes" or point 2 is "no" then the income is only foreign income and not foreign-sourced income and hence taxable in Singapore regardless remitted or not.
If they are right then it's not possible to do this in Singapore.
 
This is what I got from my service provider regarding offshoare taxation:


If they are right then it's not possible to do this in Singapore.
They are wrong.

https://www.iras.gov.sg/taxes/corpo...-companies/companies-receiving-foreign-income
Foreign income refers to income derived from outside Singapore. Generally, such income is taxable in Singapore when remitted to and received in Singapore. Where the foreign income arises from a trade or business carried on in Singapore, it is taxable in Singapore upon accrual, regardless of whether it is received in Singapore.
 
You may want to read the long conversation I had with xshore
https://www.offshorecorptalk.com/th...ture-for-offshore-taxation.43973/#post-290227
There I posted even the law to provide a clear answer. Foreign income is tax free if not remitted. Just be sure not to believe that a local guy there can do consulting for a US client as this is not foreign income but local income.

https://sso.agc.gov.sg/Act/ITA1947?ProvIds=P13-#pr10-
10.—(1) Income tax is, subject to the provisions of this Act, payable at the rate or rates specified hereinafter for each year of assessment upon the income of any person accruing in or derived from Singapore or received in Singapore from outside Singapore in respect of —

(25) To avoid doubt, it is declared that the amounts described in the following paragraphs are income received in Singapore from outside Singapore whether or not the source from which the income is derived has ceased:
(a)any amount from any income derived from outside Singapore which is remitted to, transmitted or brought into, Singapore;
(b)any amount from any income derived from outside Singapore which is applied in or towards satisfaction of any debt incurred in respect of a trade or business carried on in Singapore; and
(c)any amount from any income derived from outside Singapore which is applied to purchase any movable property which is brought into Singapore.
 
I just read the discussion but I see PE/office/branch outside of Singapore was mentioned so how would that apply in practice without incorporating one more company? Could rather just incorporate US LLC or BVI company (with know disadvantages) which are cheaper to maintain and zero tax I assume.
 
I just read the discussion but I see PE/office/branch outside of Singapore was mentioned so how would that apply in practice without incorporating one more company? Could rather just incorporate US LLC or BVI company (with know disadvantages) which are cheaper to maintain and zero tax I assume.
I think the rule I mentioned was that if you do services and have a PE in Singapore, you need a PE outside Singapore to be tax free. The does not apply to products and not when the is no PE in Singapore.
 
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Sorry for some delay, I was a little bit busy... I see that the debate has evolved significantly – and interestingly, in the meantime.
1) It's a software development business
Seems OK.
2) Please suggest any other option that would be a good fit where banking is easier (with EMI support).
Well...
Honestly, I do not consider myself being extremely knowledgeable re: company incorporation (re: banking I'm better oriented).
But from what I heard and/or witnessed:
1) US LLC in a state with zero state tax (NM, WY, NV, DE ...) is really not a bad option; although it's maybe less powerful as SG company (see debate above), the issues are quite simple and banking is well manageable.
2) Channel Islands are not so frequently used but I consider it as an alternative really worth checking.
3) Inside EU there are also some options that are used, as Estonia, Polish special IT regime or Romania, possibly somehow combined with Cyprus or Malta non-dom. Not zero tax in all cases but there are another pros, like quite easy banking etc.
EDIT:
4) I forgot about Bahrein. I heard that some use it, too.
An agent suggested Payoneer and Airwallex for BVI banking but said none of them will offer a company card.
Payoneer in unnecessarilly expensive IMO. Airwallex is OK but for a BVI company, my clear first option would be Statrys.
Just got my own interest. Why do you want a company card to pay? Aren't cash backs much better on personal cards? And even if you pay personally, you can still get the stuff reimbursed by the company if that is needed. Or what am I missing here?
Well, in some jurisdictions it is not welcome to pay company expenses by a private card (and then reimburse) regularly, it should be just exceptional, they say. Nevertheless I do not know how it is with BVI re:this.
Generally, I understand your position.
I wanted a company card as the money wouldn't have to go through my account in case that gets reported to my country of passport so they don't get ideas to start asking questions. Maybe the company account would get reported too but haven't have issues so far at least by using an EMI.
Be advised that if you bank in an AEOI/CRS country and your residence is also in an AEOI/CRS country, your taxmen can be aware of your assets in any case. EMIs are mostly not reporting now (regardless of whether it is a company account or a private one) but it will change in the near future, e.g. in EU from 2025 (IIRC) all accounts with average 3 months balance over 10,000 will be reported.
I use Wise at the moment, they don't really know where the company is tax resident as in they never asked, they have company details and UBO details, no questions asked.
:) Well, I bet you that it will work until it stops ;)
 
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I just read the discussion but I see PE/office/branch outside of Singapore was mentioned so how would that apply in practice without incorporating one more company?

A PE/branch is not a separate company, it is just like an "office" in another country.
Registering a PE or branch typically requires rather little paperwork - but revenue that is attributable to that PE would be taxable in the other country like a local company.
 
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A PE/branch is not a separate company, it is just like an "office" in another country.
Registering a PE or branch typically requires rather little paperwork - but revenue that is attributable to that PE would be taxable in the other country like a local company.
Yes, that is also one of the use cases of the Singapore company. You register it as a PE in let's say Hong Kong. You still pay tax and all as a local company, but don't have to do audit in Hong Kong. Once you move to Bahrain, you close the PE in Hong Kong and register it in Bahrain. It gives you more freedom as you can keep the company. That's where Singapore comes handy as let's say a German company will challenge on every move and try to get some exit or whatever taxes. In Singapore, there won't be discussions as it is tax free from start.
 
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Hi all, I want to incorporate a company in Gibraltar to receive royalty income.

However, is it true that although income from outside of Gibraltar is untaxed, royalties will be regardless of where they come from?

What if I do not remit them to Gibraltar, are they then untaxed under the company?
 
You will need to apply for tax exempt status and you cannot have local income. Also, the company cannot be managed from Gibraltar.
How do you apply for tax exempt status in Gibraltar?
 
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