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)
Please login or register to join the discussion.
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?
You haven't said what sort of work they will be doing in Fiji, or how long a short time is...
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