UK Subsidiary with Singapore Directors

How would tax and DTAs come into play?

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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

  1. Will The UK Company still have access to DTA benefits it has with other nations? Namely EU, US, and Japan.
    1. If not, what does it mean for the UK Company?
       
  2. Does hiring a non-resident director who operates outside of the UK to negotiate and close contracts via the internet constitute a Permanent Establishment?
    1. This would mean that the PE profits are taxed twice correct?
    2. Will the director be taxed on his/her income?

Thanks!

Replies (1)

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By Matrix
01st May 2017 11:25

I refer you to the limitation of benefits article in the US/UK tax treaty.

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