Cross-Border Tax Structure Review
Budget: $10 – $30 USD
I'm relocating to Korea and need a 1-hour consultation on my multi-jurisdiction setup:
- European creative consulting company billing non-Korean clients
- Offshore IP-holding company in Hong Kong (nominee director in place)
- Top-level holding in Georgia UBO
- Profit flows: ~90% billed from EU to HKCo, remainder retained in EU
- Cash‐out via either low-tax dividends or shareholder loans
Korean issues:
- Jeonse deposit vs. shareholder loan
- Mortgage structuring
- Permanent Establishment (PE) risk
- Freelance (sole-prop) invoice implications
Scope:
1. Is the Georgia layer necessary?
2. Can HKCo alone suffice as a passive holding?
3. Any PE/CFC traps under Korean law?
4. Best way to handle jeonse deposit and financing
5. Loan vs. dividend extraction compliance
6. Invoicing as a sole-prop without extra Korean tax exposure
I’m looking for an expert in cross-border tax law, especially concerning Korea, the EU, and offshore jurisdictions.
- European creative consulting company billing non-Korean clients
- Offshore IP-holding company in Hong Kong (nominee director in place)
- Top-level holding in Georgia UBO
- Profit flows: ~90% billed from EU to HKCo, remainder retained in EU
- Cash‐out via either low-tax dividends or shareholder loans
Korean issues:
- Jeonse deposit vs. shareholder loan
- Mortgage structuring
- Permanent Establishment (PE) risk
- Freelance (sole-prop) invoice implications
Scope:
1. Is the Georgia layer necessary?
2. Can HKCo alone suffice as a passive holding?
3. Any PE/CFC traps under Korean law?
4. Best way to handle jeonse deposit and financing
5. Loan vs. dividend extraction compliance
6. Invoicing as a sole-prop without extra Korean tax exposure
I’m looking for an expert in cross-border tax law, especially concerning Korea, the EU, and offshore jurisdictions.