Switzerland Holding Company owning UK LTD, where to pay tax?

[clemens]

I maintain and run a dozen companies. One of our setups is a Switzerland Holding company that own 100% of the shares in the UK LTD - it is registered as a daughter company. How is it taxed, in Switzerland or in the UK ?

All activity goes out from Switzerland!

 

[Marzio]

How is it taxed, in Switzerland or in the UK ?

If the UK LTD is tax resident in UK then it pays UK corporate tax.

 

[clemens]

How can it be tax resident in the UK if there is nothing there, everything is controlled from Switzerland ?

 

[Marzio]

How can it be tax resident in the UK if there is nothing there

Where is the director resident?

UK LTD is considered tax resident in UK in case of statutory seat and little substance.

 

[clemens]

Where is the director resident?

Switzerland.

 

[Marzio]

You have to request a tax residency transfer and it has to be approved by HMRC, then the UK LTD will be exempt from UK CIT

INTM120070 - Company residence: 'Treaty non-resident' companies - HMRC internal manual - GOV.UK

www.gov.uk

 

[clemens]

You have to request a tax residency transfer and it has to be approved by HMRC, then the UK LTD will be exempt from UK CIT

INTM120070 - Company residence: 'Treaty non-resident' companies - HMRC internal manual - GOV.UK

www.gov.uk

Thank you, will do that. Wasn't aware of the rules since I had not the chance to ask our tax consultant about it.

 

[Onassis]

Where is the director resident?

UK LTD is considered tax resident in UK in case of statutory seat and little substance.

Where is this table from?

 

[Marzio]

https://www.government.nl/binaries/government/documenten/reports/2021/12/12/comparative-analysis-of-the-taxation-of-conduit-companies/PwC+comparative+analysis.pdf