Tax residence in Georgia and have HK offshore company

[Lolloeoicrypto]

I am a tax resident in Georgia and want to set up an offshore company in Hong Kong for a marketing services business. I plan to appoint a nominee director. Is this possible, or in practice, will they say that the company lacks substance in Hong Kong and require me to pay taxes in Georgia?

 

[AtlasShrugged]

Does Georgia enforce their CFC rules?

 

[JosephLL]

Does Georgia enforce their CFC rules?

Introduced in 2021. However , it seems that entity is not treated as CFC if:

* Registered in juriadiction with >15% CIT
* Not holding
* Annual revenue < 1M GEL

 

[JosephLL]

But , yet again, I think CFC rules are not relevant before the mysterious PE/PEM conditions are established here ...