For a UK non-dom, are dividends taxed if issued from an offshore company controlled in the UK

[babaorum]

If one:
- files taxes in the UK as a non-dom
- has a company in an offshore tax-haven
- the company is controlled by him so the company's profits are taxed in the UK at 19%
- the company issues him dividends paid into an foreign account

Will the dividend be considered foreign-sourced and not be taxed
OR
UK-sourced because despite the company being abroad it is UK-controlled and taxed, and so the dividends will be taxed as well?

 

[Martin Everson]

UK-sourced because despite the company being abroad it is UK-controlled and taxed, and so the dividends will be taxed as well?

Yes

 

[babaorum]

Yes

Do you have a source? I couldn't find any HMRC guidance on this.

 

[CaptK]

You run the company from UK and are actively managing it therefore your non dom structure is useless.

 

[wheelspin]

Is there a tax liability if the company would be held by a trust or foundation? Do the CFC rules kick in?

 

[Martin Everson]

Do you have a source? I couldn't find any HMRC guidance on this.

Pay a tax advisor to tell you what I just told you perhaps.

Is there a tax liability if the company would be held by a trust or foundation? Do the CFC rules kick in?

Depends on if you have UK sourced income.

You can always call HMRC's trust helpline and explain that you are a non-dom.