Non resident UK LLP - who/where Pay tax?

[ccmonger]

Hi,
I understand that non resident UK LLP is a pass-through meaning the partners will need to pay tax in their respective countries and not in the UK.

But what if the partners of the LLP are:
1. Georgian company
2. Individual

Can the partnership to set to 100% Georgian company ownership
0% individual ownership

And then only the georgian company will have to pay tax in Georgia?

Would be nice if anyone could clarify this subject.
Thank you!

 

[justanotherguy]

Can the partnership to set to 100% Georgian company ownership
0% individual ownership

Partnership still requires 2 or more co-owners.

Here are 2 ways you can do it:

1. Register 2 Georgian companies and put them as shareholders, but it gets complicated.
2. Register UK ltd, put the Georgian company as the owner, and get the Treaty non-resident' companies" status, more on it: Register a non-resident company for Corporation Tax

The LTD route is safer, because the partnership route can result in double taxation and tax issues.

 

[ccmonger]

Partnership still requires 2 or more co-owners.

Here are 2 ways you can do it:

1. Register 2 Georgian companies and put them as shareholders, but it gets complicated.
2. Register UK ltd, put the Georgian company as the owner, and get the Treaty non-resident' companies" status, more on it: Register a non-resident company for Corporation Tax

The LTD route is safer, because the partnership route can result in double taxation and tax issues.

What's the issue with
Partner 1 - 100% Georgian company ownership

Partner 2 - 0% individual ownership
?

 

[Sols]

A party isn't a partner if they own 0%.

 

[ccmonger]

A party isn't a partner if they own 0%.

What about 99/1?

 

[Sols]

What about 99/1?

Yes, that works.

 

[churumbelo]

I had a consultation with an accountant some time ago and asked him whether the members should register for self-assesment since are not resident nor have business in the UK, hence they should not be liable to pay tax in the UK. He said that's right, but if we ask (and obtain) for an exemption to the HMRC first.

I don't know if true or not.