My wife and I are have recently moved to Portugal and after taking advice here have started a Portuguese Ltd to encompass both my work (web development) and my wife's (fashion print design and selling vintage clothing). I have also recently shut down my UK Ltd, which I used to offer software contracting services.
At a recent meeting with our Portuguese accountant he advised that my wife may now need to open a UK Ltd for her vintage business, which she was previously self-employed for in the UK, as there is technically no activity in Portugal despite our residency here. In particular the goods she sells are not stored in or ever transported through Portugal and therefore he thought that UK VAT would be applicable rather than a VAT reverse charge from the Portuguese Ltd. He advised that my web development business and my wife's print design business (as services businesses in Intellectual Property) should be run from the Portuguese Ltd.
Regarding my wife's vintage business, she sells vintage clothing to fashion brands, it's all B2B. The stock is stored in the UK, primarily bought in the UK (although also France, occasionally Portugal, occasionally US) and sold in the UK and France at industry trade shows around 8 times / year (6 x events UK, 2 x events Paris) which she essentially "commutes" to from Portugal. The thing I am unsure of here is that because we are now tax resident in Portugal, would that make Portugal the "centre of control" of a UK Ltd, or would the fact that effectively all operations are carried out in the UK be ok here?
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I don't think you should seek Portuguese tax advice on a UK forum!
UK VAT will be due if goods are being sold from the UK to UK customers.
Are you worried about the "centre of control" for VAT or Corporation Tax purposes (the two have different rules)?
Yes you will need to be VAT reg in the UK if stock is bought, stocked and sold in the UK to UK customers.
Does the UK company have a seat of control in Portugal? yes. Does it have a permanent establishment? probably not. What does the DTT say?
If you have a problem it will not be with HMRC as they will be happy to take your tax all day long, it will be if Portugal want to treat the company as resident there (again you need to check the DTT)
We deal with a number of clients in exactly this kind of situation, pm me if you want more help.
Some sort of group structure with cross charges for work done in Portugal? Who looked after the UK side before - ask them to see it through as they know your circumstances