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UK Resident - HK Company - How to keep central management & control non-UK?


New member
Hi all,

I run an eCommerce business (have stock and sell in the US and EU) currently out of a UK LTD company as I'm a UK resident.

I'm aware that if I want to switch over to a HK company, I need to prove to HMRC that the company is centrally managed and controlled outside of the UK.

A lot of the advice regarding CM&C online is for large companies (e.g. Ensure the majority of shareholders are non-UK etc.) and mine just has me as a director.

Now I'm happy to fly abroad and conduct all my board meetings with minutes in France, Spain etc. but will this be enough for HMRC to accept that central management and control is non-UK?

I'm not sure if it makes a difference, but we have no physical ties (ownership of property) to the UK other than we have inventory stored there and sell to customers there, and of course have a UK resident as the only director.

Thanks very much


New member
pay attention. The key to be able to have a company in HK is substance. But having substance there also makes you be taxed there (16% as far as i know).
That 16% + company cost, is it worth it?


Active Member
Nope. You would probably have to find local office, local staff etc.
And also suddenly you have increased costs for accounting and audits.

All this to save 2.5% points on corporate tax. 17.5 vs 20.


I make things happen
Silver Member
Hire a local accountant that can be the director. Taxes are officially 16.5% but it's 6.5% for the first £200.000 on profits and you can deduct almost everything as expenses. To don't mention that you can build an offshore company somewhere else and derivate the profits with the IRD not bothering
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