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Moving crypto assets & IP from UK to BVI

upallnight

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Hello all,

Have very much enjoyed reading this forum over the last few weeks, but have struggled to find much guidance on tax efficiently shifting assets offshore.

I have a crypto related company based in the UK with a 7 figure balance in an Ethereum wallet, plus some brand and software IP that could be argued to be worth a reasonable amount of money.

I’ve just set up a company in the BVI with the intent to have all future crypto income going into it. My outstanding questions (that my accountants have given views on but I’m not convinced it can’t be better optimised) are:
  • After paying UK taxes on this income, how would I shift both our Ethereum wallet funds and IP over from the UK ltd co to the BVI co tax efficiently, and without breaking any tax evasion related laws? I have not yet created a direct link between the Ethereum wallet and the UK company (i.e. cashing out funds to our UK bank acc) in the event that there was a way to declare those funds to the BVI company, however it doesn't appear there is. Hence why I will likely declare those funds to the UK co and pay tax there.
  • Am I at any risk of an investigation in future due to links to the UK company and it all just being pushed off shore? I am open to both leaving the UK company open with a smaller part of non-crypto business running through it, but I would also be happy to close it down if it made more sense.
  • I understand I’ll likely need a ‘mid-shore’ company in the likes of Cyprus as the operating business, or as a service business for paying out things like my dividends or salary. Could that play a part in moving the assets?
  • I don’t particularly want to live in the BVI, but I am very flexible in where I base myself. No partner, no kids, have been bouncing around countries for years. How can I avoid a country deciding my business owes local taxes there if I’m working on the business day to day from that country? Do I need to distance myself as being the business operator with staff running operations locally in BVI or Cyprus, for example? Portugal's NHR could be an option but I do worry about being caught out for leading and operating the business from there, even if I am being paid in dividends.
Any thoughts are very appreciated on any of the above.

If anyone offers advisory service in relation to working out my above situation, I'm more than happy to pay for that advice, please drop me a reply.

Thank you.
 
Last edited:
Easy way to find some invoicing service that can help you send invoices for the crypto amounts. Requires a more complicated explanation but we have discussed it here before.
 
Where is BVI's place of operation, management and control?

You are also aware that BVI will report the IBC automatically to your home country?

 
Where is BVI's place of operation, management and control?

You are also aware that BVI will report the IBC automatically to your home country?


Right now the BVI co's registered office is our law firm's HQ in Tortola. I am currently 100% of management and control, although I know that likely needs to change. I just have the firm set up with 0 funds or assets at the moment.

I don't intend to do anything that isn't by the book, so I'm unsure in BVI reporting the IBC to UK is an issue?

I don't currently live in the UK, and I'm in the process of doing the paperwork to formally leave as a tax resident going into the new tax year.

Appreciate your info & thoughts, thank you.
 
Right now the BVI co's registered office is our law firm's HQ in Tortola. I am currently 100% of management and control, although I know that likely needs to change. I just have the firm set up with 0 funds or assets at the moment.

Registered office and place of operation are totally different. So place of operation is UK or where management and control is exercised which is with you in UK.

I don't intend to do anything that isn't by the book, so I'm unsure in BVI reporting the IBC to UK is an issue?

It will be reported to UK.

I don't currently live in the UK, and I'm in the process of doing the paperwork to formally leave as a tax resident going into the new tax year.

You say you don't live in UK but doing paperwork to leave UK?

The address you gave your agent is where company will be reported to regardless of where you sleep at night.

P.S Well you definitely did things in the wrong order :(. You should have left UK officially before setting anything up. HMRC will have fun with you for years to come with this new company reporting. They may wait some years then hit you with an audit by which time the company may have assets.
 
Can you give a bit more of an explanation of Crypto related?
Assuming that the Crypto currently sits outside of the company, you set up the entity and inject the crypto and use it as seed.
If you are willing to leave the UK then that would be the best place for your structure currently.
With the above you can live anywhere but ideally a tax free country as your base.
 
Assuming that the Crypto currently sits outside of the company, you set up the entity and inject the crypto and use it as seed.
that could work actually.
 
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The issue here is that the crypto was generated via a token campaign relating directly to the UK company's brand. So I believe that if we were investigated, and the UK co's resources were used to create the token campaign, and the brand of the UK co, it would be deemed the revenue should have been allocated to the UK co.
If you have not declared the payment and it's not shown anywhere on the books then you can swap it out.

Basically swap your crypto from another unrealted source. Then do as I said above.
 

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