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Corporation tax on offshore online company

Corporation tax on offshore online company

The usual no physical business scenario: a company run entirely from a laptop is formed as an offshore company in a no-tax jurisdiction. It is owned and management by the same person, so management and control pull tax residence to where that person lives. What I am wondering now is how it works in practice if that person starts moving about. Say for example:

January 13 - March 13: In the UK

April 13 - August 13: Travelling about

September 13 - June 14: In Germany

June 14 - July 14: Travelling about

August 14 onwards: Next country

Now what happens to his personal residency? Will he remain UK tax resident until the end of March (when he leaves), until 5th of April (end of tax year), or end of August (when he starts being in the place where he will aquire his next tax residency)?

What about his next residency (in this case Germany)... when would it start, when would it end?

And presumably the company tax residency is where management and control is. Does that mean where he physically is? Or where his personal tax residency is? And if it is where he physically is, what happens during the travelling bits?


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25th Dec 2012 14:04

Need of specialist advice


HMRC's current view, to paraphrase it (after a very nice lunch and bottle of Rioja),is that in order to become non-UK resident you need to demonstrate residency elsewhere, and no UK residency.

So until September 13 the business is UK resident, from then until residency elsewhere probably German resident, but not conclusively non-UK resident,

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