Tax Efficiency: UK LTD + US LLC Strategy to 0% Tax - Any Insights?

[stivemoose]

Hello everyone,
I've been contemplating a strategy and would appreciate some insights. The concept involves setting up a UK LTD with myself as the director (I reside in Portugal under NHR) and as shareholder my LLC in Delaware. The key premise is that, by refraining from engaging in trading activities within the UK and maintaining transactions under £10 million, corporate tax in the UK can be avoided. All UK earnings would then be directed to the Delaware LLC with 0% tax.

I've come across this idea from a colleague, but I'm uncertain about its viability and whether it's a path worth exploring.

I welcome any opinions or advice on this scheme. The primary objective is to channel income to the US without incurring UK taxes, utilizing the UK solely for more convenient trading (considering factors like bank accounts in euro for example, etc.).

Thanks in advance for your insights!

 

[Sols]

If you are director, the UK company becomes tax resident in Portugal. That defeats the purpose of and goes against NHR, but Portugal isn't really doing much to enforce that part of their tax code, so you'll probably be fine for the near future.

The key premise is that, by refraining from engaging in trading activities within the UK and maintaining transactions under £10 million, corporate tax in the UK can be avoided.

What's the basis for this?