Information regarding double tax treaty with Fiji

Working in Fiji through a UK Ltd company do you need a specific form for Double tax treaty

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Hello My client wants to work in Fiji for a short time and wants to work through his UK ltd company as he has losses b/fwd and wants to use those up.

I see there is double tax treaty with Fiji and the UK.  it says on hmrc website  if you have a certificate of residency and there is double tax treaty you do not have to pay tax in a foreign country.  (so Fiji should not deduct any tax)

Has anyone done this with Fiji before and know if you need any other form besides the COR? (certificate of residence)

I don`t want to claim the foreign tax credit as I want to use the losses in the Ltd company.

 it says on hmrc website some countries need a form by their own country which needs stamping  by HMRC. I am not sure if this relates to Fiji. anyone with any experience of this please  advise.

 

Please advise 

 

Thanks

 

 

 

 

Replies (5)

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By Montrose
16th Feb 2019 13:58

see:-
https://assets.publishing.service.gov.uk/government/uploads/system/uploa...
and scroll down for the appropriate UK forms.
But are you confusing corporate profits in Fiji with personal earnings?

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By WhichTyler
16th Feb 2019 19:49

You haven't said what sort of work they will be doing in Fiji, or how long a short time is...

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By Paul11
18th Feb 2019 14:55

Client is working for 6 months in Fiji through a ltd company as a consultant.

Will he be able to be paid his earnings gross in Fiji and not have any Fiji corporation tax deducted in Fiji on his Ltd company earnings ?

Otherwise it will be a case of claiming foreign tax credit and then I won`t be able to use the losses in his Ltd company if thats the case.

I thought there was a double tax treaty for companies as well as individuals in Fiji. It says there is on the HMRc website. You can apply for COR for a UK company in Fiji with the aim I am guessing of not paying corporation tax in Fiji. I thought that was the whole point of a double tax treaty. You will see if you scroll down to form RIS1 for companies.

On this link : https://www.gov.uk/guidance/get-a-certificate-of-residence

It says apply for A COR so you do not get taxed twice abroad. I am trying to find the correct form so my client will not pay fiji corporation tax while he is abroad.

I appreciate your help with this. Thanks

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Replying to Paul11:
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By WhichTyler
18th Feb 2019 15:29

Over my head now. If you are satisfied that he won't have a PE there, and that the provisions of the Art14 on professional services don't apply, that is on your professional judgement.

If you want to know what attitude the Fijian authorities might take, or what case law is, you might want to make contact with a local accountant

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