Why not incorporate in Ireland?

....or any other low tax jurisdiction for that matter?

Didn't find your answer?

If you are starting a buisness in the UK is there any reason why you cannot just incorporate your company in Ireland instead and enjoy a lower Corporation Tax rate? You would still be trading in the UK, but as a foreign entity. All profits would then be taxed at the Irish rate of 12.5% presumably?

I assume there would a bit more paperwork and hassle, but this could easily be worth it for the tax saving. Obviously any distributions would still incurr UK tax as this is based on where the individual is resident, but you would have more to distribute in the first place. Even Entrepreneurs relief would be available wouldn't it?

Surely it can't be that easy.... there must be a catch somewhere?

 

Replies (16)

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abc
By Kim Jong Un's Hair
06th Mar 2017 12:18

You don't happen to advise Google, do you? [***]!

You appear to be considering the individual's residence status but not that of the company. More homework needed.

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Replying to Kim Jong Un's Hair:
abc
By Kim Jong Un's Hair
06th Mar 2017 12:18

Swearing filter?

Not a fan.

Not a [***] fan.

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Replying to Kim Jong Un's Hair:
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By Mr_awol
06th Mar 2017 12:42

Quote:

Swearing filter?

Not a fan.

Not a [***] fan.

Me neither. Looks [***]

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By Dick Stastey
06th Mar 2017 12:33

Have you read the tie-breaker for company residence in the UK/Ireland treaty? Rhetorical question.

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paddle steamer
By DJKL
06th Mar 2017 12:39

No need, just wait until Phil announces his budget -the UK as the pariah low tax offshore capital of Europe.

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By Ruddles
06th Mar 2017 13:03

Why stop at Eire? Why not incorporate in BVI for instance? The question is of course rhetorical.

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By Harrison88
06th Mar 2017 13:38

Read "Permanent Establishment".

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By sawebs
06th Mar 2017 18:54

Could someone just explain rather than just put "read xyz"? Is that because you don't really understand it?

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Replying to sawebs:
By Ruddles
06th Mar 2017 19:15

Why do people think they need to be spoon-fed the answer? A bit of effort often helps the information to stick.

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Replying to Ruddles:
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By sawebs
06th Mar 2017 19:55

Quote:

Why do people think they need to be spoon-fed the answer? A bit of effort often helps the information to stick.

Because I can go and read up the detail in my own time when convenient, whereas a quick précis by someone with years of experience could distil it into a few sentences and satisfy my curiosity. I don't need to set aside a few months to read the Quran if someone explained the main themes and messages - but it may give me enough interest to go back and read it sometime.

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Replying to sawebs:
paddle steamer
By DJKL
06th Mar 2017 19:34

Try reading, for a start, attached re HMRC guidance as an intro:

https://www.gov.uk/government/publications/issue-briefing-taxing-the-pro...

Here is somewhat more detailed guidance:

https://www.gov.uk/hmrc-internal-manuals/international-manual/intm120000

And in particular:

https://www.gov.uk/hmrc-internal-manuals/international-manual/intm120060

Ask yourself where the company's central management and control will rest.

Trust this assists you in considering that country of incorporation is merely one test re residence and being within the charge to UK corporation tax.

Edit:- Even if non resident consider whether or not it would be trading through a permanent establishment in the UK.

(CTA 2010, s 1141(1)): per Bloomsbury Tax Annual

It has a fixed place of business there through which the business of the company is wholly or partly carried on, or
an agent acting on behalf of the company has and habitually exercises there authority to do business on behalf of the company.

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By Matrix
06th Mar 2017 22:09

If a company is managed and controlled in the U.K. then you would normally expect it to be within the charge to corporation tax regardless of where it is incorporated.

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Replying to Matrix:
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By sawebs
06th Mar 2017 22:13

Quote:

If a company is managed and controlled in the U.K. then you would normally expect it to be within the charge to corporation tax regardless of where it is incorporated.

Perfect. Thanks, wasn't that difficult was it? I had read up in the meantime and that confirms what I thought I had surmised from many pages of information.

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Replying to Matrix:
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By sawebs
06th Mar 2017 22:13

Quote:

If a company is managed and controlled in the U.K. then you would normally expect it to be within the charge to corporation tax regardless of where it is incorporated.

Perfect. Thanks, wasn't that difficult was it? I had read up in the meantime and that confirms what I thought I had surmised from many pages of information.

Thanks (1)
Replying to sawebs:
By Ruddles
06th Mar 2017 23:06

Quote:
I had read up in the meantime

Wasn't that difficult, was it?

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Replying to sawebs:
Stepurhan
By stepurhan
07th Mar 2017 09:54

Quote:

Perfect. Thanks, wasn't that difficult was it? I had read up in the meantime and that confirms what I thought I had surmised from many pages of information.

Remind me. How much are you paying the respondents here to do your work for you?

Good to see that AccountingWeb continues to fill up with entitled [***] that considers the other members their servants to to dictate to as they wish.

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