The treaty non-resident UK Ltd. - the best-kept offshore secret?

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If the goal is to pay tax in Hong Kong or UAE at lower rates than UK and you are actually living there and not in UK, it will most likely work. You may even consider a private letter ruling. I am aware of companies that did this, not with UK but other two countries.

If you start using nominee directors, you will most likely run into troubles once you have an audit. The tax guys in Europe are known to audit companies at the place of management and ask questions to the directors. If you have some random dude there, it will cause troubles.

If you do not report or pay tax in Hong Kong, it will be considered tax evasion in the UK and not Hong Kong. This is also one of the reasons why foreigners doing business in China always pay full amount of tax there while the locals are less tempted to pay the full amount. Also beware that even Hong Kong tax audits and investigations are no longer just on paper, they actually start chasing your tax. Hence, I do not think that not paying tax in UK and then claiming offshore in Hong Kong will work very well. This because the conditions to claim offshore most likely contradict the requirements of the DTA to not pay tax in UK.

The currency is generally not a problem. You must simply convert your profit, turnover, etc. to the local currency at rates given by the tax authorities. Hong Kong recommends to keep the books in the relevant currency, which may be USD or something else. I would recommend you too. Imagine, you have 10M GBP assets and do little trade. If your books are in HKD, your profit or loss goes up and down each year just based on the fluctuating exchange rate, distorting your real profit. If your books are in GBP, your profit is what you actually earn.

Also note that for the case in Hong Kong, you will get around the mandatory CPA audit.
 
But which country is it being taxed at low rate?

1.
For example, I think that Montenegro 9%, Hungary 9%, Bulgaria 10%, Bosnia 10% and North Macedonia 10% are interesting.

https://www.gov.uk/government/publications/montenegro-tax-treatieshttps://www.gov.uk/government/publications/macedonia-tax-treaties
But, I think about a practical issue here. I think it is easy to find a nominee director in the UK. UK nominiee directors understand the position as nominee directors but then, it is much more difficult to convince someone to become a director in these low rate countries. I think it is the number one problem because these nominee directors would be responsible for the Corporate income tax reporting duty in their country of residence.

2. About VAT.
Foreign companies can register for VAT in the UK to collect and deduct UK vat for distant selling for instance. So, i guess it is possible.
 
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I think it is the number one problem because these nominee directors would be responsible for the Corporate income tax reporting duty in their country of residence.
money talks bulls**t walks! Why would it be difficult to buy a person in one of the mentioned countries? you can buy everyone there.
 
If you want, I will be your director in North Macedonia if you want. I will register and be there until I get the passport. But you will find locals who can do it for you for very little money, trust me. Just a matter if you have access to the right people.
 
okay, thank you, and sorry to say so, I realize it is my fault
 
Do you have a reliable source to find such a nominee in the UK - the one I have found so far are almost not available any longer.
 
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