So how does the Agent of Undisclosed Principal work and can it be substituted by an LLP with a UK partner owning a 5% share and the non UK partner/s owning the rest?
Let's start with the directors and shareholders: How does their place of residence affect the operation of this structure? Need they all be UK resident, non UK resident or does it not matter?
If the agent does not "carry on a trade in" the UK (which means sells into the UK as far as I can fathom, am I right?) the principal is not taxed in the UK. What if the principal is not from a jurisdiction with a UK DTT?
The LLP is fiscally transparent it is claimed. Does that mean that (assuming not trading in UK) a single uk corporate partner would pay CT on its share of the profits only and the offshore partner(s) would not, or would they have to pay CT and offset it against tax in their home jurisdiction and if that is lower how can that be recovered if at all?