UK LTD corporate tax if no link with UK

[toums]

I was using in the past a UK ltd (as holding) for one of my local Hungarian company, to be able to take the dividends without WHT between the HU and UK companies.

If for any reasons the UK ltd starting to bill directly for some services, consulting or whatever, is there any easy/legal way to avoid CIT in UK, if this UK ltd has : no UK citizen/resident director, no decision or no management from UK, no office there and no UK customers?
Simply if in that case the UK ltd can be considered as PE where the decisions are took.

My current accountant said, even with 0 link with UK and no activity, business, and clients in UK, if I Bill anything from this UK ltd, if profit, UK CIT should apply in any case.

Any advises ? thanks

 

[diatessaron]

Do as your accountant says.

 

[Debrog]

Search for "UK Agency Company" or "UK Agency agreement" here

 

[daniels27]

Yes, if you bill from the UK company, HMRC would want taxes from you. But as per the DTA, your UK company is actually a tax resident in Hungary where you live. Hence, you would have to register a branch in Hungary for your UK company and then pay all taxes there. Then find somebody who explains this to HMRC and then you would be good. I personally would recommend you to use a US LLC or something which is normally used for non resident companies as the process are easier and most likely cheaper and less risky.

 

[Marzio]

is there any easy/legal way to avoid CIT in UK

Only if you make the UK LTD treaty non resident in HU but why would you start billing from UK LTD?

 

[toums]

Yes, if you bill from the UK company, HMRC would want taxes from you. But as per the DTA, your UK company is actually a tax resident in Hungary where you live. Hence, you would have to register a branch in Hungary for your UK company and then pay all taxes there. Then find somebody who explains this to HMRC and then you would be good. I personally would recommend you to use a US LLC or something which is normally used for non resident companies as the process are easier and most likely cheaper and less risky.

Till now I am tax resident in Portugal under NHR. From 2025, I will be tax resident in Thailand (if no more bad news regarding tax law there).
The HU company is because i use it for flip in real estate (buying and reselling).

I have the possibility to bill some extra services remotely, thats why I was thinking to bill directly on the UK ltd, but if I have to pay the UK CIT, then no point to do it.

 

[Marzio]

if I have to pay the UK CIT, then no point to do it.

Use a US LLC then

 

[toums]

Use a US LLC then

Any recommendation for the juridiction ? With the less paperwork/yearly paperwork, and easiest/fastest.
I dont need stripe. Just wise account for some Sepa transfer IN.

 

[daniels27]

Any recommendation for the juridiction ? With the less paperwork/yearly paperwork, and easiest/fastest.
I dont need stripe. Just wise account for some Sepa transfer IN.

Yes Wyoming
https://www.wyomingagents.com/

 

[Marzio]

I'd add New Mexico since they don't ask for annual report and fee.