Just thinking about something today and thought perhaps better answers could be secured here.
If a UK Company is established 'say way back many years', the UK company is a technology company as in it's in the stage where money is thrown into said company or rather money is passed from the owner/founder/ceo to the parties that are not employees but overseas developers, the owner/ceo/founder is non resident in said country - say resident in a country with territorial tax system, the funds flowing into the company is their money or that of their family.
the UK company owns the asset 'code' - informal non-IP protected code.
after a number of years the owner/ceo/founder generates a new company 'overseas' in another location to the UK company, and a different the location of their residence, say a tax haven with 0% tax.
the Company overseas generates revenues which are for a product/service that is used against the IP/technology which it has license to turn into a product/service, after which the technology is then transitioned to the overseas company as a Asset for free/nominal value.
The UK company is ceased in the tax year as it doesn't serve a function and wouldn't be viable due to regulations or domestic laws.
The overseas company then starts paying out to its consultants/staff/employees from its revenues where-ever they are based in the world.
Is there any taxable income on that UK company?
If a UK Company is established 'say way back many years', the UK company is a technology company as in it's in the stage where money is thrown into said company or rather money is passed from the owner/founder/ceo to the parties that are not employees but overseas developers, the owner/ceo/founder is non resident in said country - say resident in a country with territorial tax system, the funds flowing into the company is their money or that of their family.
the UK company owns the asset 'code' - informal non-IP protected code.
after a number of years the owner/ceo/founder generates a new company 'overseas' in another location to the UK company, and a different the location of their residence, say a tax haven with 0% tax.
the Company overseas generates revenues which are for a product/service that is used against the IP/technology which it has license to turn into a product/service, after which the technology is then transitioned to the overseas company as a Asset for free/nominal value.
The UK company is ceased in the tax year as it doesn't serve a function and wouldn't be viable due to regulations or domestic laws.
The overseas company then starts paying out to its consultants/staff/employees from its revenues where-ever they are based in the world.
Is there any taxable income on that UK company?
