Tax residence in Georgia and have HK offshore company

Lolloeoicrypto · 2025-03-17T12:19:31+0100

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 · 2025-03-17T13:16:19+0100

Does Georgia enforce their CFC rules?

JosephLL · 2025-03-17T15:49:03+0100

AtlasShrugged said:
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 · 2025-03-17T15:52:16+0100

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

daniels27 · 2025-03-17T17:52:18+0100

Lolloeoicrypto said:
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?

In theorty, it is possible that they will deny the offshore exemption and ask you to pay taxes in Hong Kong if you do not pay taxes in Georgia, although there are not many reports where it happened. We discussed this a couple of times.

Tax residence in Georgia and have HK offshore company

Lolloeoicrypto

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