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Structure business moving from UK to UAE Offshore

I have a profitable one-man-band UK Ltd company. I used to be a UK resident, but am no more, and I am in a jurisdiction where I can take dividends at 0%. I wish to move my company to UAE offshore for tax purposes so I'd pay no corp tax, however some of my largest customers wish to remain under the UK company.

How would it possible to share "the product" with both companies? What kind of agreement needs to be written? Is it that the UAE offshore company would buy the product from the UK company, and license the UK company to use it?

Also, which company should bare the expenses? Can I put the expenses on the UK company?

Tip: You guys are awesome.
 
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A lot depends on what the company does. For example, there's a difference between digital and physical goods as well as between digital and physical services. You might want to speak with a UK attorney or tax adviser about it, to make sure you don't accidentally do something wrong. This is an area with a lot of anti-avoidance type regulations that are easy to miss if you're going about it on your own.

There many ways to go about this.

One would be for the UAE company to buy the whole UK company. This usually allows for easier transfer of assets (product, customers) than between two otherwise unrelated parties. Consider the other implications of this, though, such as banks and payment processors performing immediate repeat KYB on your business.

Another is for UK to sell or license the product to UAE, which would enable UAE to offer the same product. You can look into transferring customers separately.

Two big things to keep in mind here is data protection (GDPR) and UAE itself.

Make sure that if you transfer data about any EU or UK persons to UAE it's done correctly with all relevant informed consents obtained from the data subjects.

UAE is currently on the FATF gray list, which may affect how the aforementioned anti-avoidance rules are triggered.

I'd also recommend looking into other options besides UAE, that would allow you to transfer your biggest client as well. Why do they insist on staying with UK? Would they accept Isle of Man? Or a UK LLP?
 
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The company sells cloud software product.
Technically nothing is going to change for customers except the business address. Even the contracts will remain under England jurisdiction. There is no data transfer to UAE or any physical presence in UAE.

It’s unclear why this one large customer disagreed as I don’t have direct connection with their legal team, and communication isn’t that seamless.

I wouldn’t use Isle of Man as Stripe is not supported. I’d have to change the entire payment system which is going to be months of work. All systems I use already work with UAE.

I’d rather leave any UK tax liabilities as the laws are draconian… but in any case who would the other part of UK LLP be?
 
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I’d rather leave any UK tax liabilities as the laws are draconian… but in any case who would the other part of UK LLP be?
If you can't find another person to fill the role, a common method is to form another company. It can be the second member of the LLP. Then you can structure the agreement so that you still get all the profits yourself.

However, keep in mind that income from an LLP might not be treated as dividends where you live now, so make sure you check the relevant tax laws with an expert.
 
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