Question about EU companies and Delaware LLC

[limitx]

Hi guys...

I have a question that almost no accountant could answer with confidence.

We have a commercial service company (Company A) in Bulgaria.

We want to create a Holding Company (company C) in Cyprus that will have a Delaware subsidiary (company B) and Company B will be invoicing company A for consulting or for holding intellectual property rights.

We know that opening a bank requires info for the UBO.

So the question is... Is that structure doable nowadays? Will the Bulgarian bank/authorities require info about the Delaware company? What are the possible issues?

Any ideas would be helpful...

 

[Sols]

This sounds like a question for your lawyers/tax advisers in Bulgaria and Cyprus.

In theory, the structure is probably fine but there are dozens of details that can affect how it's perceived by the tax authorities. There is increased aggression towards intellectual property holding structures.

The Bulgarian bank may request KYC on the Delaware company. Or it might not. It's entirely up to the bank and it's a decision they take based on all the information available to them.

If you're using the US entity to for example dodge VAT, the Bulgarian tax authority might be upset if/when they figure out your scheme.