tax implications for money transfer from US LLC to UK personal bank account

[AndaV]

Hello. Are there any tax implications of transferring money from a US LLC Wise bank account to a personal UK bank account (associated with a previous UK residential address). The account holder is currently a tax resident of nowhere. She was a tax resident in the UK a few years ago (but had another tax residence for 1 year after leaving the UK, spends fewer than 16 days per year in the UK, and does not carry out any work in the UK). Thank you.

 

[Xshore]

Is the llc disregarded? If so, probably no from the US side. And if you're not tax resident in the UK then there won't be any UK tax due when receiving money into a UK bank account.

 

[AndaV]

The US LCC is a disregarded entity in the US. The LLC owner is no longer tax resident in the UK and in fact spends zero days in the UK, so according to the presence test she is non-resident. However, the clients she invoices through the US LLC are in the UK. So the payments from the UK go to her US LLC bank account in Belgium, and then the money is transferred from the business bank account to the UK personal accounts (which still has a UK address on them). Does this cause any concern about income source taxation or center of vital interests in the UK?

 

[SCHLOSSFINANZ]

yes paid-outs only to a non UK account