Question Any UK citizens on here with an IBC?

[robbie777]

For the long term I am thinking about setting up a company in Anguilla and follow its citizenship by investment program and eventually become a permanent citizen on the island. But at present I am a UK citizen paying UK taxes.

The questions I have is for any other UK citizens on this forum that already has an IBC in the caribbean. I don't have a LTD company in the UK and not looking to set up one either. I know I would have to fill out CT600B or CT600J if I had a UK ltd company with a subsidiary company abroad but If I don't have a UK LTD I am unsure what forms I need to file. I have tried contacting HMRC a dozen times and having no luck getting any reply from them at all on the matter.

Knowing that the company is going to be in Anguilla, it is not an exempt country on the list and has to pass through a cfc gateway. Do anyone know what I have to file if I pay myself from the Anguilla company? Would it still the the CT forms even though I do not pass the profits through a LTD company or can I pay myself and only mention it on the self assessment return?

Any helpful information from someone who is a UK citizen and has an IBC would be greatly appreciated.

Or if anybody knows of a UK accountancy that deals with offshore companies and UK tax that would also be great.

 

[Martin Everson]

If your sat in UK then place of operation for an IBC would be where the directors are resident hence UK. In general terms the offshore company will be transparent to HMRC if you are the owner. Hence all income of offshore company distributed or not distributed and even where you could benefit from it WILL be attributed to you personally and taxed as such under personal income tax rates. UK has tough anti avoidance rules as you may know

P.S The place of operation of an IBC can never be in the country of incorporation by the very nature of an IBC being an offshore company having to operate outside its country of incorporation.

I would seek professional tax advice before proceeding.

 

[robbie777]

Thanks for replying.

There is also a LLC option in Anguilla but I am unsure if the UK would see it as opaque as it does a US LLC. I will have to look more into it.

 

[Fazoule]

@Martin Everson I see every this advice (good advice indeed) however I might have contacted 20 UK chartered accounts and there wasn't even ONE that was capable of answering the question of what tax to pay / what form to fill when having an IBC being a UK resident...

Would you be able to share a list of firms that would be able to help us in this regards? Or at least what kind of accountants we need to look for on Google (what kind of keywords?) ?

 

[robbie777]

@Martin Everson I see every this advice (good advice indeed) however I might have contacted 20 UK chartered accounts and there wasn't even ONE that was capable of answering the question of what tax to pay / what form to fill when having an IBC being a UK resident...

Would you be able to share a list of firms that would be able to help us in this regards? Or at least what kind of accountants we need to look for on Google (what kind of keywords?) ?

I found these guys.. they are UK accountants that deal with offshore companies and UK residents

https://www.taxinnovations.com/specialist-tax-planning/non-uk-structures/offshore-companies/

 

[CaptK]

HMRC will regard you as self employed and make you liable on profits.

 

[robbie777]

HMRC will regard you as self employed and make you liable on profits.

Problem being it will pass through the cfc gateway. Meaning I could face corporation tax in my situation.

 

[CaptK]

You need to pick your poison because both are viable arguments. Choose one and go down that road.

 

[Martin Everson]

I found these guys.. they are UK accountants that deal with offshore companies and UK residents

https://www.taxinnovations.com/specialist-tax-planning/non-uk-structures/offshore-companies/

Yup they are saying exactly what I said. That for a UK permanent tax resident the offshore structure is transparent and offers nothing in terms of tax savings.

Would you be able to share a list of firms that would be able to help us in this regards? Or at least what kind of accountants we need to look for on Google (what kind of keywords?) ?

You will find very few tax accountants with proper cross border structure experience outside of those that service High Net Worth Individuals. Most will now not bother to help you due to the below. It will bring them nothing but trouble to help the average joe.

https://www.offshorecorptalk.com/th...eporting-comes-into-effect-1-july-2020.29711/

 

[Martin Everson]

There is also a LLC option in Anguilla but I am unsure if the UK would see it as opaque as it does a US LLC. I will have to look more into it.

You need to examine HMRC's internal manuals. They see it as Opaque as they state below.

https://www.gov.uk/hmrc-internal-manuals/international-manual/intm180030

 

[robbie777]

You need to examine HMRC's internal manuals. They see it as Opaque as they state below.

https://www.gov.uk/hmrc-internal-manuals/international-manual/intm180030

Awesome .. thanks for this. HMRC manual is so large it is like a maze.