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Malta trading + UK Ltd holding: corporate tax return in the UK?

PrestoR3

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Dec 27, 2020
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Hi

I have the following structure:

- Me (tax resident in Malta)
- Malta trading company
- UK Ltd holding company (parent of Malta trading for receiving tax-free refunds from Malta gov)

QUESTION: Does anyone with the same setup manage to find an accountant in the UK who will actually submit a proper corporate tax return for the UK holding with Malta subsidary?

BACKGROUND:
I know that most of the accountants in Malta will advise you that it's fine for the UK company to submit dormant tax returns and that it UK holding doesn't even need to have a bank account. They will tell you that it's safer etc. I don't personally feel comfortable with it... if it's all legal why it's "safer" to hide it?

Ultimately, how UK parent company can receive dividends from the MT subsidiary + a refund from the MT gov and keep reporting that it's dormant?

I want to close this structure and if there is any tax due in the UK holding (which I think is not - based on my research) I will pay it and move on. However, I can't find an accountant in the UK that will know how to handle it.

MY EXPERIENCE THUS FAR:
- Local non-international accountants are getting freak out and want to pay taxes everywhere. Ideally twice, just in case

- The international UK accountants I approached thus far never worked with structures like this. However, they will be happy to start a full-blown international tax analysis on my situation and charge 200 GBP per hour on engagement and the result will be unclear

- Maltese firms, as I mentioned before, will advise you grey-area solution (in my opinion) to submit NIL accounts in the UK. Mostly because they don't really have a lawyer in the UK and they feel it's safer like that. Just because that's how they always did, not they actually have knowledge about UK taxation

Does anyone know a UK accountant that can help to make it right for a "reasonable price"?
 
QUESTION: Does anyone with the same setup manage to find an accountant in the UK who will actually submit a proper corporate tax return for the UK holding with Malta subsidary?
Plenty.

BACKGROUND:
I know that most of the accountants in Malta will advise you that it's fine for the UK company to submit dormant tax returns and that it UK holding doesn't even need to have a bank account. They will tell you that it's safer etc. I don't personally feel comfortable with it... if it's all legal why it's "safer" to hide it?
Such is Maltese culture.

Does anyone know a UK accountant that can help to make it right for a "reasonable price"?
Check with Appleby, Vistra, and BDO. I have seen them all work with Malta setups before.

Depending on what exactly you need from them, you're looking at a few thousand GBP setup and anywhere from just a few hundred to a few thousand GBP per year for all the necessary filings.
 
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BACKGROUND:
I know that most of the accountants in Malta will advise you that it's fine for the UK company to submit dormant tax returns and that it UK holding doesn't even need to have a bank account. They will tell you that it's safer etc. I don't personally feel comfortable with it... if it's all legal why it's "safer" to hide it?

You may want to read the below thread fully. We debated Malta + UK Holding companies. Using an artificial construct to gain a tax advantage may be legal in Malta but I would plan ahead. I have never felt comfortable with it either.

 
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@Martin Everson I absolutely agree with you. I know a lot of people doing it like that and they have no problem whatever. Fair enough. But for me now when I know more about it thanks to this forum, I'm also not feeling comfortable with it.

I decided to move to Cyprus. I will have single company there. I will pay what they want and I will close this structure. That's why I'm looking for accountant that will make sure I won't have problems in the UK.
 

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