An Irish ltd co. set up a uk ltd company with the intention of operating a sales and distribution operation here.
They have decided to rather sell and distribute from Ireland as they have tax losses they want to use up (and no doubt eventually benefit from the lower corp tax rate).
Therefore they have a UK subsidiary with one higher rate employee doing software development work. The UK company pays the salary and the Irish co pays the UK co.
Would the Irish co. and the UK based employee be better off, if he was employed directly by the Irish co. in the UK?
