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Best company jurisdiction for UK non-dom selling online services?

OverseasCoder

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Jan 9, 2019
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Hi,

I am a UK non-domiciled and taxed on the remittance basis. I am in UK ~6 months of the year and rest I am abroad traveling.

I have income from app and software sales (licensing) as well as some digital consulting, not originating from the UK.

Now I am looking to incorporate a company to handle this as revenue is growing. I've been looking at different jurisdiction for forming the company.

Clients are mostly from EU and would prefer if the company was not in a greylisted country such as Belize etc. I've been looking at Cyprus resident companies (12.5% tax, no withholding), but to my understanding there is a risk that the company could be regarded as UK taxable, right? I guess the same goes for all other jurisdiction.

Also looked at US LLCs, but I guess the same is a risk for these? Ie. central management can be viewed as carried out in UK, thus becoming UK taxable on both a corporate (19%) and personal level (40%).

Do anyone here have a recommendation for a jurisdiction for this case?

Thanks!
 
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risk that the company could be regarded as UK taxable, right? I guess the same goes for all other jurisdiction.
welcome aboard.

That's correct, it's almost mandatory to have a local tax advisor / lawyer by hand if you want to deal with this since the tax authorities in all EU member countries (I know UK is on the way out) going crazy.
 
Yeah wait until after brexit.....if it happens ns2. Non-dom status may not exist much longer if labour government comes to power :(.
 
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You are correct. The problem is control. What is likely to happen is that an overseas company will not incur the corporation tax at the normal UK rate as the UK can't really apply this, but you would be expected to declare the profits of the company as income on your tax return in the UK.
 
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Make sure to have enough "substance" into your foreign company (office, Real director, employees....ect)
All the management, and decisions have to be taken outside the UK, even Emails phone calls, and meeting have to be done outside the UK.

If you manage your foreign company from the UK, your foreign company can be taxed as a UK one.
I would recommend you to have a European company ( Cyprus, Malta, Ireland...).

Can I ask you what's your country of origin ?

Yeah wait until after brexit.....if it happens ns2. Non-dom status may not exist much longer if labour government comes to power :(.

Do you really think they can stop this statuts ? Non doms pay a lot of taxes in the UK and I am not sure they will stop this status. In 2015 115,000 non-doms paid as much tax as 10 million low-income workers !!!
 
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Control and Managament of the company is the key to tax freedom wherever you live. It's difficult to proof for simple company setups that both is in the country of registration. It will most often require a real office, staff, phone, electricity and even a local director.
 
Do you really think they can stop this statuts ? Non doms pay a lot of taxes in the UK and I am not sure they will stop this status. In 2015 115,000 non-doms paid as much tax as 10 million low-income workers !!!

Sadly we live in a post facts world proved by brexit vote...so yes it may happen. I don't think the average working class UK chav will care about what you said as that is not how it will be explained to them :(. It will be explained like "Wealthy dirty foreign tax evaders are living in UK and not paying tax on their worldwide income like ordinary british folk do and we can't have this any longer in UK"...lol ns2.
 
First world is for third world tax evaders. Like Pakistani PM (UK , France) etc.

Same goes to third world. Third world is for first world tax evaders. Ahaha beauty is endless.

Hi,

I am a UK non-domiciled and taxed on the remittance basis. I am in UK ~6 months of the year and rest I am abroad traveling.

I have income from app and software sales (licensing) as well as some digital consulting, not originating from the UK.

Now I am looking to incorporate a company to handle this as revenue is growing. I've been looking at different jurisdiction for forming the company.

Clients are mostly from EU and would prefer if the company was not in a greylisted country such as Belize etc. I've been looking at Cyprus resident companies (12.5% tax, no withholding), but to my understanding there is a risk that the company could be regarded as UK taxable, right? I guess the same goes for all other jurisdiction.

Also looked at US LLCs, but I guess the same is a risk for these? Ie. central management can be viewed as carried out in UK, thus becoming UK taxable on both a corporate (19%) and personal level (40%).

Do anyone here have a recommendation for a jurisdiction for this case?

Thanks!

What you think about China?
 
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