We would like to point out that the tax concepts and calculations shown on this website are only examples and illustrative; they are also not complete in some cases. DUNAMIS MIND accepts no liability and gives no guarantee that they are up-to-date, complete and correct.
Binding advice is given by us exclusively in personal contact on the basis of a corresponding order agreement.
We assist in the establishment of business using an English company.
UK trading company as subcontractor
A UK company may enter into a contract with another company B, whereby the other company B provides the UK company with business opportunities and the know-how and key personnel to carry out the business. These bases usually entitle Company B to a significant proportion of the UK company’s trading income. Payments made to Company B are tax deductible by the UK company.
In an alternative arrangement, Company B is the owner of the business with all the opportunities and risks and is therefore the contractual partner of the customer. The UK company provides its name, bank account and administrative infrastructure so that Company B conducts its business in the name and with the infrastructure of the UK-Ltd.
UK company registered in the UK but not resident for tax purposes
A UK company can be tax resident in two countries at the same time (currently Malta, Madeira, Switzerland, Cyprus) and the relevant double taxation agreement assigns the right of taxation to the other country (not UK). Thus, the tax burden can be reduced if the tax burden in the other country is lower, as well as avoiding the taxation of financial statements in the UK in the event of migration.
UK-LLP with non-UK resident members
An English Limited Liability Partnership (LLP) is a partnership with limited liability which must have at least two members and has its own legal personality. The LLP is not itself taxable, but the profits are allocated directly to the members as trading income for tax purposes. Where the members of a UK LLP are not resident in the UK and the LLP also does not trade in the UK, the members are not liable to UK tax on the LLP’s profits.
UK company as a Discretionary Trustee
UK companies can act as discretionary trustees (administrators) for trusts (foundations under Anglo-American law).
Under English tax law, a trust has the status of an independent entity for the purposes of income and capital gains taxation. A trust where at least one administrator is resident in the UK is resident and taxable in the UK. A Discretionary Trust where the founder is neither UK resident nor domiciled and has both UK resident and non-resident administrators is called a mixed-resident trust and is treated for tax purposes as a non-UK resident for the purposes of income and capital gains taxation. However, the trust’s corporate seat remains in the UK.