UK Ltd formation by non resident (has DTA with my country)

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noname

New member
Hi guys,

I would appreciate it if someone with more experience and knowledge can explain this to me and give me a correct answer. I am interested in UK LTD formation (main reasons are better reputation with customers worldwide, ability to apply for payment gateways originally not supported for businesses in my country, ability to sell apps on Google Play Store - at this moment Google does not accept merchant registrations for my country). So, I am a resident of Bosnia and Herzegovina and the UK has DTA with my country.

According to this DTA agreement, it says:

The provisions of the MLI came into force in the UK on 1 October 2018 and in Bosnia and Herzegovina from 1 January 2021 and are effective for:
  • taxes withheld at source, from 1 January 2021
  • Corporation Tax, from 1 April 2022
  • Income Tax and Capital Gains Tax, from 6 April 2022
  • all other taxes levied by Bosnia and Herzegovina, for taxable periods beginning on or after 1 July 2021
My idea is to use my current Bosnian company to register and own the UK LTD company.

Does this DTA agreement mean that after 1, 6 April 2022 (if nothing changes by then) I am paying corporate tax and other taxes in my home country and that I am free of paying taxes to the UK? The UK LTD company would have Wise EMI accounts and mainly be used to receive payments from other companies such as Apple, Google for apps revenue, maybe from Stripe and PayPal. I do legitimate online business backed by documentation as contracts, invoices.

I was thinking about the US Delaware LLC, but now that I saw we have DTA with the UK and not with the USA, maybe the UK is a better option for me as I would be somehow safe and clear since I pay tax normally here where I live. I never had a company abroad and I want to avoid troubles with tax authorities.
 

bilderberger

New member
You can’t have corporate directors of UK companies. Will the control of the company be in your own name at your Bosnian address?

What will the substance of the work be, and where are your customers located?
 

noname

New member
You can’t have corporate directors of UK companies. Will the control of the company be in your own name at your Bosnian address?

What will the substance of the work be, and where are your customers located?
Okay, so the way is that I register UK ltd on my name and to be the director and owner. Business is selling digital goods ( Apps and subscriptions ) to customers located worldwide mainly the US, but some are UK too. Sales tax is paid to the UK for UK sales by my payment processors.
 

fshore

Entrepreneur
The UK company can become treaty non resident, meaning you tell hrmc that it's resident in the other country and then you don't have to file to hmrc (still have to file accounts to Companies House).
You might have to register the UK company as a foreign company doing business in Bosnia, and register for Bosnia local sales taxes etc.

Maybe instead it can work to register a branch in the UK of your Bosnia company.
 

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