This is my first post on AccountingWeb and I would like to ask you a question.
I would like to set-up an UK LLP as a holding company. The LLP will have two partners: myself (UK resident) and a non-resident company (BVI). This LLP will fully own three or four UK LTD companies from which will receive dividends.
The partnership will not actually conduct any trade but will just receive dividends from the LTDs.
- Will the dividend income allocated to the non resident partner (BVI company) be taxed or will it be treated as disregarded income?
I understand that dividend income can generally be treated as disregarded income for non-residents however Guidance HS300 Non-residents and investment income (2017) says: "Disregarded income doesn't include a share of partnership investment income. "
- Will this mean that the non-resident partner will have to pay UK Tax on their share of the dividend income?
- Would it be better in this case to set-up an UK LTD rather than a LLP?