App business - Income from Adsense and other US companies

Hello,

I am an EU citizen and resident.

I have an app served through App Store and Play Store generating around $4.5M per year considering both advertising revenue and subscription revenue paid directly by Apple and Google.
Our digital business has very high margins in the order of 80-90% and we are currently operating with a limited company (SRL) in a very high tax country of EU (Italy).
We want to move away from Italy and are trying to figure out the best setup we could do.

We receive most of the payments from big US companies like Google, Apple, AppLovin etc., and have very few incoming payments with big amounts involved coming every month, mostly in USD.
Only Google, since we are operating from Italy with an Italian company, pays us through Google Ireland in EUR (around EUR 150k per month) but we can create another Google Adsense account based in US for example and get paid in USD (if we have a US LLC obviously).

Looking at different topics on the forum UAE seems a good fit to relocate, the problem is that since there is no tax treaty between USA and UAE Adsense applies a 30% withholding tax which we want to avoid. (Adsense and all the other US based networks force you to sign a W8BEN-E for companies or W8BEN for individuals where you have to specify the tax treaty you want to leverage if you want to avoid the 30% tax)

I tried to figure out a different solution like a US LLC owned by me as a tax resident of a country that has no income tax, but I found that usually those countries like UAE, Caymans, Bahamas, etc do not have any tax treaty with the US, and this can be a problem.
Someone in the forum mentioned Georgia but I prefer to have residency in a country where English is talked by most of the people there or at least is very common and where there is a western-like culture.
Also, I was looking for a country where there is no minimum stay (or at least like the UAE where to keep your Visa you have to come back to UAE once every 6 months, so no minimum 180 days period).

I am also possibly evaluating more complex structure schemes involving different companies in different jurisdictions (and maybe which do not involve changing my residential country directly).

I am open to solutions and feel free to ask me any additional questions if needed.

Thank you very much!

uplana said:

I would look into the UK or Ireland for your business activity most often you will have some very good tax benefits as an foreigner. Personally I'm looking into the UK for relocation with an accounting firm to clarify the tax benefits there may or may not be.

Thank you. Does the UK have a corporate income tax of 19% ? Do you mean like using a UK LLP or by being a UK non-dom resident? With UK LLP the problem would be the same since I would need residency in a country with a tax treaty with the US.

I was trying to look at a 0 tax solution if possible.

Ireland is not an option because you would be paid by Google Ireland that will also charge VAT if you are an Ireland company.

uplana said:

yup - that's also what I look into at the moment.. have a "meet" meeting with an accounting firm this week, can update here if things are positive.

Thank you, I will wait for some news, hope they are good! :)

If anyone else has some advice please let me know!

Thank you!