Non dom moving to the UK

[UkNonDom]

Hello,

I am considering moving to the UK from Belgium. I currently hold 100% of the shares of a belgian limited by shares company. From what I've gathered, I can currently make use of the non dom rule for the first 7 years without having to pay the £30,000 remittance amount.

Now, obviously, I would prefer to keep the majority of my income outside of the UK unless I would actually need it. How do I achieve this through use of a holding company structure?

This is how I currently see it:
The best way seems to be to structure all of my assets in an offshore holding company (cayman islands, jersey, ..) that then pays me yearly dividends and/or a bonus into an offshore account. I would then be able to spend this money tax free abroad or pay tax on the amounts brought back into the UK. Is this correct?

Also, how do I make sure my holding company is then not regarded as a having UK based management and control? I have read that trusts may be able to offer a solution to this by settling the shares of the holding company in the trust before moving to the UK. The trust would then be regarded as a non resident and thus the company would not be regarded as UK based. Is this correct?

Thanks!

[maths]

If I may say, this is too complex a subject for me (others may disagree) to provide any definitive guidance. The UK has many anti-avoidance provisions re offshore structures which apply to both UK and non-UK domiciled individuals.

As a very general comment, it is often better to avoid using trusts and companies if at all possible from a pure tax perspective.

Certainly, as you suggest, ensuring offshore companies are not UK resident for UK tax purposes can be difficult in practice (if not in theory). Offshore trusts are not cheap and can be "messy".

I might be more inclined to set up a number of bank accounts offshore each of which is to receive different categories of offshore income/capital gains; inheritances; gifts etc; it is then possible to arrange for remittances to the UK from the account which precipitates the "best" UK tax position. In addition, you have direct control over such accounts