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Sark, Andorra, Guernsey, UK Structure..... Possible?

Barney2201

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Feb 19, 2017
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In the last year we have moved from Guernsey to Sark, spent the winter on Sark, lived in Mauritius and South Africa under our Sark tax status and now planning our next move....

Have a UK (real) business with turnover £2.5million to £3million and a pre tex profit of circa £700K - £1million

We very nearly moved to Portugal, but a lack of high quality housing for 'reasonable' money on the Algarve and the kids were not keen on schools meant we didn't bother.

Wife wants to return to Guernsey, I don't which means we are now looking at a hybrid solution.

Looked at many options but Brexit on a UK passport is a killer for Europe and I need to be within reasonable commute of London but also want a 'lifestyle' destination, so sun or ski or both!

After looking at many of the tax effective options such as Malta, Cyprus, Gib etc it would appear the Sark deal is still the best.

You can rent a very modest property for £9K per year, and Sark tax law states you are considered resident if you have 'access' to accommodation over 90 nights per year.

You cannot register a company there but there are no CFC rules, transfer pricing etc. Many people on Sark have companies in the BVI.

However, Sark is impractical and frankly dull in the winter, very wet & windy and the ferry service to Guernsey is one or two a day and no ferries on a Sunday in January until March, so not ideal.

In the summer Sark is pretty idyllic and not a bad place to spend a few months.

I 'bounce' in and out of the UK up to the 90 midnight rule, I can spend time in Guernsey and will have some accommodation on Sark, but need a third destination as a 'bolt hole' and looking at Andorra.

Appreciate it's not an idea commute with a 2hr drive but better than 4.5hrs to Cyprus and great skiing etc.

Our company will be based in Guernsey as my wife will reside there full time and therefore she will be the 'substance' on the island for the business.

Can anyone tell me if Andorra has a maximum nights (or days) you can stay in the country?

I believe you can be stamped out of Shengan on entry to Andorra and again back into Shengan on departure, all I can find is you are not allowed to spend more than 90 days in the country but nowhere does it say if that's per year or in one hit. I would stay between 90 - 180 so I don't become tax resident (yet) but it nicely gets me around the 90/180 Shengan rule which I am already into by 70 days in the last 140.
 
In the last year we have moved from Guernsey to Sark, spent the winter on Sark, lived in Mauritius and South Africa under our Sark tax status and now planning our next move....

Have a UK (real) business with turnover £2.5million to £3million and a pre tex profit of circa £700K - £1million

We very nearly moved to Portugal, but a lack of high quality housing for 'reasonable' money on the Algarve and the kids were not keen on schools meant we didn't bother.

Wife wants to return to Guernsey, I don't which means we are now looking at a hybrid solution.

Looked at many options but Brexit on a UK passport is a killer for Europe and I need to be within reasonable commute of London but also want a 'lifestyle' destination, so sun or ski or both!

After looking at many of the tax effective options such as Malta, Cyprus, Gib etc it would appear the Sark deal is still the best.

You can rent a very modest property for £9K per year, and Sark tax law states you are considered resident if you have 'access' to accommodation over 90 nights per year.

You cannot register a company there but there are no CFC rules, transfer pricing etc. Many people on Sark have companies in the BVI.

However, Sark is impractical and frankly dull in the winter, very wet & windy and the ferry service to Guernsey is one or two a day and no ferries on a Sunday in January until March, so not ideal.

In the summer Sark is pretty idyllic and not a bad place to spend a few months.

I 'bounce' in and out of the UK up to the 90 midnight rule, I can spend time in Guernsey and will have some accommodation on Sark, but need a third destination as a 'bolt hole' and looking at Andorra.

Appreciate it's not an idea commute with a 2hr drive but better than 4.5hrs to Cyprus and great skiing etc.

Our company will be based in Guernsey as my wife will reside there full time and therefore she will be the 'substance' on the island for the business.

Can anyone tell me if Andorra has a maximum nights (or days) you can stay in the country?

I believe you can be stamped out of Shengan on entry to Andorra and again back into Shengan on departure, all I can find is you are not allowed to spend more than 90 days in the country but nowhere does it say if that's per year or in one hit. I would stay between 90 - 180 so I don't become tax resident (yet) but it nicely gets me around the 90/180 Shengan rule which I am already into by 70 days in the last 140.
Do you mind if I ask you why don't you stay in Mauritius, as there are direct flights to London and the sun all year round?
I think Switzerland is the best option in your case due to tax efficiency, direct flights to Guernsey and Swiss alps.
Another suggestions would be Monaco and San Marino.
 
Can’t do Bahamas as running a UK work day and need to be in London almost weekly.

We lived in Mauritius earlier in the year and it was a nice lifestyle (although still a 3rd world element), but again, 3hrs ahead which moves to 4hrs in UK winter, if you have family it makes it tricky when you start work at 1pm but the kids go to school at 8am.

Switzerland is interesting but I am not EU (UK passport) so no automatic right to live there, would need to jump through some hoops to take up residence. Anyone have any experience of this on a UK passport?

Monaco is the same issue as Switzerland, would first need a French long stay visa. Is Monaco still imposing the ‘must have €500k liquid’ in a bank to register as resident or can you just rent a property avd become resident?

For sure, if your looking for low tax, easy ‘bouncability’ to the UK and have a UK passport the world becomes a very small place…. Hence ending up living on Sark last winter.
 
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Can’t do Bahamas as running a UK work day and need to be in London almost weekly.

We lived in Mauritius earlier in the year and it was a nice lifestyle (although still a 3rd world element), but again, 3hrs ahead which moves to 4hrs in UK winter, if you have family it makes it tricky when you start work at 1pm but the kids go to school at 8am.

Switzerland is interesting but I am not EU (UK passport) so no automatic right to live there, would need to jump through some hoops to take up residence. Anyone have any experience of this on a UK passport?

Monaco is the same issue as Switzerland, would first need a French long stay visa. Is Monaco still imposing the ‘must have €500k liquid’ in a bank to register as resident or can you just rent a property avd become resident?

For sure, if your looking for low tax, easy ‘bouncability’ to the UK and have a UK passport the world becomes a very small place…. Hence ending up living on Sark last winter.
Consider the Italian flat tax: €100k, 2 pages tax return, no hassles for 15 years.
 
Can’t do Bahamas as running a UK work day and need to be in London almost weekly.

We lived in Mauritius earlier in the year and it was a nice lifestyle (although still a 3rd world element), but again, 3hrs ahead which moves to 4hrs in UK winter, if you have family it makes it tricky when you start work at 1pm but the kids go to school at 8am.

Switzerland is interesting but I am not EU (UK passport) so no automatic right to live there, would need to jump through some hoops to take up residence. Anyone have any experience of this on a UK passport?

Monaco is the same issue as Switzerland, would first need a French long stay visa. Is Monaco still imposing the ‘must have €500k liquid’ in a bank to register as resident or can you just rent a property avd become resident?

For sure, if your looking for low tax, easy ‘bouncability’ to the UK and have a UK passport the world becomes a very small place…. Hence ending up living on Sark last winter.
As @Johnydoe said. Italy is option if you can afford pay 100kEUR/year. But still it's tax.
Monaco is an option if you can afford to put in bank and invest 500-2mEUR. It depends case by case and luck to open bank account in Monaco. Depends on your personality, risk and business profile. You can rent decent apartment in Monaco for ~5k EUR
 
I wouldn't trust anything coming out of Italy law/tax wise (not being racist or whatever about Italians, love em to bits.) But they have a tendency to be flexible about legalities
Your approach is right, but there is no reason to change this law, which is now 5 years old. Also remember that changes take a very long time in Italy to happen.
 
If you enter by car they do keep an eye on numberplates entering the country, however I am not sure wheter or not they are actively about it. I mean I don’t think they would really bother with Guernsey plates.. It’s more to track locals, french and spanish plates.
 
Regarding Italy, maybe the remote worker visa will start soon - but like most tax specials in Italy including the 100k flat tax option there is a shortage of comprehensive guides covering all the important details - such what social taxes must be paid and calculated on what gross income, how long before exit taxes start to apply, etc. I have read there are few applicants to the 100k scheme due to those other details. However i am not any kind of tax expert about Italy but i would like to know if Italy offers a simple residency option that wasn’t surrounded by all the other Italian tax problems.
 
Regarding Italy, maybe the remote worker visa will start soon - but like most tax specials in Italy including the 100k flat tax option there is a shortage of comprehensive guides covering all the important details - such what social taxes must be paid and calculated on what gross income, how long before exit taxes start to apply, etc. I have read there are few applicants to the 100k scheme due to those other details. However i am not any kind of tax expert about Italy but i would like to know if Italy offers a simple residency option that wasn’t surrounded by all the other Italian tax problems.
In the Italian 100k flat tax are zero extras such as social taxes etc. You file a 2 pages return, don’t declare any earnings or assets (abroad) and pay the 100k, done. Very convenient.
 
I wouldn't trust anything coming out of Italy law/tax wise (not being racist or whatever about Italians, love em to bits.) But they have a tendency to be flexible about legalities
I wouldn't trust anything coming out of Italy law/tax wise (not being racist or whatever about Italians, love em to bits.) But they have a tendency to be flexible about legalities
that's hilarious haha
 

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