Hey all,
We're looking to start a wholly owned UK Subsidiary to help manage/distribute our IPs, this is to take advantage of the preferable DTAs in place when it comes to Royalty Withholding. US > SG Royalty Withholding is currently at 30%.
The UK company will be wholly owned by the SG Company/Directors. The management will likely stem from Singapore, which based on my understanding making it a Singapore Tax-Resident. We will hire one of the SG directors to perform business duties such as contract negotiation, and a UK part-time/contract basis accountant to make sure our taxes are filed correctly.
Questions are as follows
- Will The UK Company still have access to DTA benefits it has with other nations? Namely EU, US, and Japan.
- If not, what does it mean for the UK Company?
- If not, what does it mean for the UK Company?
- Does hiring a non-resident director who operates outside of the UK to negotiate and close contracts via the internet constitute a Permanent Establishment?
- This would mean that the PE profits are taxed twice correct?
- Will the director be taxed on his/her income?
Thanks!