Tax efficient companys structure advice

[yorkie49]

Looking for advice on the following companies structure set up to optimize Corp tax.

10 properties in the UK which pay monthly rent to xxx property management company ltd, the prop mgt co then pays xxx investment company ltd (who owns all the property's) a high monthly rent for occupying one off its offices. Could we then set up an offshore xxx holding company with a share swap with the share holder of the investment company in BVI for example and then pay fees out of the xxx investment company to an offshore account held by the BVI holding co. Moneys built up in the offshore account would be used to purchase property for rent in SE Asia on behalf of the holding company. I am just experimenting with possible structures any comments appreciated.

[bd6759]

The current structure is confusing. All the rents belong to the investment company and should be in its accounts. The management company could receive a payment for managing the properties, and it can pay rent for using an office, but both these must be at market rates.

Any offshore company will be taxable in the UK, assuming that you are UK resident.

[yorkie49]

Yes all rents would go to the investment company, and yes the UK management company would receive a 15 - 20% commission. Any rent paid by the management co would be at market value. However if a payment is made to an offshore company from the investment company why does the off shore company pay tax in the UK.

[bd6759]

Since the holding company does no more than hold the shares in the investment company, why would it be getting any fees?

A company, wherever registered, is resident in the country from where it is controlled and managed. If you set up and run a BVI company, it will be resident in the UK.