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?
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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.
Have you read the tie-breaker for company residence in the UK/Ireland treaty? Rhetorical question.
No need, just wait until Phil announces his budget -the UK as the pariah low tax offshore capital of Europe.
Why stop at Eire? Why not incorporate in BVI for instance? The question is of course rhetorical.
Could someone just explain rather than just put "read xyz"? Is that because you don't really understand it?
Why do people think they need to be spoon-fed the answer? A bit of effort often helps the information to stick.
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.
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.
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.
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.
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.
Remind me. How much are you paying the respondents here to do your work for you?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.
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.