We have long standing client who estatblished an internet based business in several years ago (he is sole shareholder and is one of two directors) . His personal circumstances dictated that he moved overseas but has continued to run the company in UK as a non-resident director. Our client is now looking to establish an offshore company in a territory with no DTA but would like to distribute the income via the UK company. The idea being that the offshore company will be a 100% subsiduary which will then pay dividends up the UK company who will in turn pay corporation tax on the dividends due to the fact there is no DTA in place. As the company is controlled and managed from outside the UK as from what I have read so far there doesn't appear to be an issue in doing this but would be most interested if anyone can see a problem by structuring in this way.
Thanks
Gary
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Taxation of Non-Resident Company 100% owned by UK Company
Hi Gary,
Hope it is not too late...and you have already sought tax advice
Depending on your client's current status my advice is to contact have an offshore consultant who can advise you on the best offshore structure
Here is his address:
VIMAL DAMRY
Managing Director
Premier Financial Services Limited
Suite 612, St. James Court,
St. Denis Street, Port Louis, Mauritius
Email : [email protected] - [email protected]
Tel : +230 2136703 - Fax : +230 2136704 - Cell : +230 7111639 - Skype : premiermauritius