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LLC for Greek Resident

#23
#24
troupos13 said:
I am interested in establishing an LLC in Delaware or Wyoming. In Greece, where I reside, there is no clear guidance regarding the tax treatment of LLCs. Even the tax treaty between the USA and Greece does not mention anything specific.

However, there are a few points to consider:

- The tax authority manuals state that profit distributions from offshore companies are taxed as dividends. An LLC makes a profit distribution (not dividends).
- The LLC as a company type exists in Greece, and it distributes dividends (similar to the Greek ΕΠΕ - Limited Liability Company).

There is no additional information available regarding the treatment of LLC income in Greece.

What do you think?
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As already said by a few you get taxed with your income in the US LLC in Greece unless you relocate to a low / no tax country. Alternatives would be to store and receive all your money in crypto.
 
#25
AlicaFunk said:
As already said by a few you get taxed with your income in the US LLC in Greece unless you relocate to a low / no tax country. Alternatives would be to store and receive all your money in crypto.
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Isn't this illegal to hide from the tax guys in Greece with crypto? I mean think of all the Germans that will get upset again if Greece goes bankrupt because he is not paying!
 
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#26
troupos13 said:
So? All LLC profits goes under dividend for a Greek member of the LLC from what they state?
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clear the simple question, do you live in Greek and intend to stay there, if so forget about all of what you read, you get personal taxed from any income in the US LLC!
 
#27
brianK said:
clear the simple question, do you live in Greek and intend to stay there, if so forget about all of what you read, you get personal taxed from any income in the US LLC!
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AlicaFunk said:
As already said by a few you get taxed with your income in the US LLC in Greece unless you relocate to a low / no tax country. Alternatives would be to store and receive all your money in crypto.
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He said it will be "managed from outside" I suppose Greece. But still the question remains where it is managed from as his whole story would only work when the management uses double-entry book keeping.
 
#29
That is a very vague response he has given, and I assume he resides in Greece, which would mean everything is also managed from Greece. It seems like the OP has no interest in replying, so I assume my assumption is correct, and thus, he has received an indirect answer in this thread.
 
#30
Marzio said:
I'm waiting for you to show us any document that hints about Greece treating US LLC as tax transparent entities.
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Then Greece would indeed stand out from other EU countries, which tax their citizens on all income they earn abroad, including companies/offshore entities they manage from their home country. So, what exactly do you want to see? Try facing reality.
 
#31
@brianK see those posts in regards to the management:

daniels27 said:
Du you plan on running the LLC from Greece? Because then you can forget about those stories you mentioned, they apply to companies managed from the US.
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troupos13 said:
No, company will be managed from outside.
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daniels27 said:
From where?
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He never answered this one. It is essential in the whole story as the company manages from Germany is essentially a German company in that regards. But without reply, we can only guess.

troupos13 said:
“The following are recorded: dividends and interim dividends (prior to the deduction of any withholding tax) from foreign-listed and non-listed shares, the excess returns on mathematical reserves from individual insurance contracts of foreign insurance companies, the profit distributions of partnerships with double-entry accounting abroad, temporary withdrawals abroad, the profit distributions of trusts and offshore companies, the profit distributions of mutual funds established in third countries, and the remuneration paid in any form to members of the Board of Directors, managers, and employees from the profits of the legal entity or legal entity of foreign origin.”

Dividends are subject to a withholding tax of five percent (5%).
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That being said if the company is managed properly and in a jurisdiction without CIT and a double-entry book keeping, he would only have to pay 5% tax on dividends (as the entity is treated tax intransparent). The wht tax is completely irrelevant in this regards, it is 5% nevertheless for foreign dividends received:
https://www.taxathand.com/article/12894/Greece/2020/Taxation-of-dividends-clarified
 
#32
brianK said:
So, what exactly do you want to see?
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You said that OP will pay personal taxes from any income in the US LLC.

This means that you understand how Greece treats companies like US LLC and this understanding must come from some source.

To reply to your question I want to see any document that demonstrate that Greece sees US LLC as tax transparent because, unless proven otherwise, there's no concept of tax transparent entities in Greece.

And like Greece there are other countries that treat US LLC like opaque entities.

One of the is UK.

This is a document that says that UK treats US LLC as opaque entities.

siWeom.jpg


So unless you have proof to substantiate your claims, what you said has 0 value.

I don't care where the company is managed, this is OP problem and if he lied to us I don't care.

The point is that If he manages the company from Greece he will not pay personal taxes. He will pay Greek CIT because US LLC is an opaque entity, like managing UK LTD from Greece.
 
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#33
Marzio said:
To reply to your question I want to see any document that demonstrate that Greece sees US LLC as tax transparent because, unless proven otherwise, there's no concept of tax transparent entities in Greece.

And like Greece there are other countries that treat US LLC like opaque entities.
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Not transparent. Intransparent = opaque, etc. OP told us here:
troupos13

Post in thread 'LLC for Greek Resident'

What we declare as dividends in Greece , according to tax law :

“The following are recorded: dividends and interim dividends (prior to the deduction of any withholding tax) from foreign-listed and non-listed shares, the excess returns on mathematical reserves from individual insurance contracts of foreign insurance companies, the profit distributions of partnerships with double-entry accounting abroad, temporary withdrawals abroad, the profit distributions of trusts and offshore companies, the profit distributions of mutual funds established in third countries, and the remuneration paid...

Marzio said:
I don't care where the company is managed, this is OP problem and if he lied to us I don't care.

The point is that If he manages the company from Greece he will not pay personal taxes. He will pay Greek CIT because US LLC is an opaque entity, like managing UK LTD from Greece.
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He said he won't manage from Greece.
 
#34
Sorry, but we don't have unlimited time to answer (as someone says that op left the topic). I have also told my lawyer to check about it.

So, the results up to now are:
--
In Greece, as other countries like UK and Germany, US LLC are not treaded as tax transparent. Are treated as opaque/corporations.
In Greece, you pay for this income a tax in the rate of dividends (it was 15%, but last years 5%)

Don't say about personal income, etc as nowhere it is stated. If you have different opinion, please share it here.

About the management, we think to have an independent US manager but it is still under searching.
 
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