Share this content

Non-resident Director UK Company

Director is relocating to another country

Didn't find your answer?


I was wondering whether you have come across a similar issue before?

A client, who is the sole director of a company, providing consultancy services, is moving to Europe. The country he is relocating to has a Double Taxation Agreement with the UK, so we are not too concerned about double tax on dividends, etc...

He wants to continue running his consultancy company from abroad, working online.

He has to trade through a UK Ltd Company for commercial and legal reasons.

The question is...

His Permanent Establishment will most likely be the new EU Country, because he is based there - hence the company is controlled from there (he has no employees). Travel to the UK will be limited - to meet new clients or resolve any major issues. 

How can he go around this and keep his UK Ltd company, yet paying tax in the right place? Will he need to register a company in the new country and do management recharges, based on a transfer pricing method?

As mentioned, he has  to trade through a UK Ltd Company for commercial and legal reasons. 

Thank you!

Replies (4)

Please login or register to join the discussion.

By Tax Dragon
28th Dec 2018 09:20

Is the question how to pay tax


in the right place?"

Why is that problematic?

Thanks (1)
By Moonbeam
28th Dec 2018 16:17

Just wondering whether this could be an issue for HMRC.

Thanks (1)
By pauljohnston
14th Aug 2019 13:16

If he is the sole direct does not his address have to be in the uk?

Thanks (0)
Replying to pauljohnston:
By Duggimon
14th Aug 2019 14:08

He needs to have an address in the UK, but does not need to live or be resident there, just be able to receive mail sent there.

Thanks (0)
Share this content

Related posts