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How will be taxed Pass-through entities in 2023 in the UAE?

Could you clarify, are you talking about US citizens or residents who is trying to avoid paying taxes in the US? Or about non-citizens as well?
I had US citizens in mind when I said that. However, no one really knows what the exact fraud algorithms used by the US government actually are. Keep in mind that you can't spend your American company's money as if it is your own personal money the way you can with a Dubai company. Like Au999 said, no employees, no infrastructure, even spending the American company's money to travel to the US could get you in trouble if someone at the IRS decides you're using the funds in a way that goes beyond reasonable business expenses and has a quota to meet. The US is a great offshore choice, but everything has to be exactly right. What you ask here should give you things to consider before going over your specific situation with an American attorney that specializes in this kind of thing. You're better off paying an attorney a few grand to make sure everything is done right than having everything blow up in your face.


Do you mean if you do B2B business and US LLC client send you a payment e.g. for marketing service to FZCO it's not deductible expense for US LLC?
Potentially. The US and various state tax codes are needlessly complex and at times nebulous. I've never personally run into an issue with an expense paid to a foreign company not being deductible, but that doesn't mean it doesn't happen. It could also be a situation where your customers would have to fill out an extremely simple form for it to be deductable and their people are too incompetent to do it. Apparently a real reason a lot of American companies won't ship overseas is because filling out a basic customs declaration form (what is in it, how much it is worth, is it a liquid, fluid, cash or cash equivalent) is too Herculean a task for their feeble-minded employees.
 
1. To connect pass through entity to Freezone entity, so that taxes will remain 0%. The only issue as always - banks. Usually, they don’t like to see UAE parent company in structure.

You can do it the other way around: Create a UAE freezone branch of your US LLC company. Then both countries should be happy.
 
You can do it the other way around: Create a UAE freezone branch of your US LLC company. Then both countries should be happy.
Yes, but it’s not easy in terms of banking, as well as you need to set up proper substance. And all of that costs pretty solid amount of $.

Looks like using only US LLC and come to uae taxman with US statements is possible as well, and doesn’t break the law, who knows.
 
No? Just use your US LLC, you don't tell anyone about the UAE branch except the UAE tax authorities...?

So normally if you operate the US LLC in Dubai - with the new CT rules, if management and control is in UAE, it will be subject to 9% CT. Are you saying if you were to add a UAE freezone branch to the US LLC structure, you could operate/manage the US LLC from within UAE without triggering management and control laws?