Best structure for international internet based Co.

L

Lobby

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Hi,

I'm looking into manufacturing some consumer electronic items. The main market for the products would be worldwide, though predominantly US/UK/Germany/Australia/China/India.

The product will be manufactured in China, and probably assembled/packaged in the US, then shipped via Louisville, Kentucky (home of FedEx).

Should the company be an Irish entity? As the product might never actually "set foot" in Ireland, maybe thats not the most tax efficient, maybe register it in a tax haven country (Caymen Islands?). Or in a specific US state (Nevada and Delaware seem to be good locations tax-wise).

All income will eventually arrive back in Ireland, so maybe the 12.5% corporation tax beats all other locations.

How best to go about this, a google search just brings up the usual list of advisors (KPMG, PwC etc.) Maybe its time to fork out a few bob and speak with these organisations?

Anyone any experience of this area?
 
Setting up your structure is well worth forking out a few bob on. My suggestion would be to have Ireland as a holding company for pooling your dividends to, a Cypriot subsidiary for lowest VAT rate to non business customers in Europe, and go with one of those states you mentioned in the US for a foreign subsidiary of the Irish parent for US sales. The idea is that you pool your dividends back to Ireland and can offset one against the other to give the best effective tax rate.

You should speak to someone though to ensure whatever setup you go with. is the most efficient. This will be money well spent. If you PM me, I can recommend someone.
 
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