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Where Taxpayers and Advisers Meet

Foreign Holding Company Owns UK Ltd

170872
Posts: 69
Joined: Wed Aug 06, 2008 3:41 pm

Foreign Holding Company Owns UK Ltd

Postby 170872 » Mon Oct 14, 2019 12:32 pm

Previous I think i posted to the wrong section.

I have a questions regarding the holding or UK company by foreign Company

Scenario
At the moment we have a Chinese restaurant business in the UK and we plan to expand the outlets. The owner of the current UK Business a Limited Company is 100% owned by individual shareholder from Singapore.

In Singapore there is a Holding company which now they planning to change the ownership of this UK company. The plan is the current UK Ltd company will be owned 100% by Singapore's holding company.

Just though i get some advice - my understanding is we need to seek HMRC for this purposed new structure.
Also the holding company will pump in money to UK to fund more outlets - is debts or Equity is the best choice?

Hope someone can shade some thoughts on both the questions above

Thank you

AGoodman
Posts: 1091
Joined: Fri May 16, 2014 3:47 pm

Re: Foreign Holding Company Owns UK Ltd

Postby AGoodman » Tue Oct 15, 2019 9:57 am

Unlikely to have any immediate tax charge on the restructuring but there is a risk of an immediate 20% inheritance tax charge if you do it wrong (e.g. individual just transfers shares to holdco).

Could be a CGT charge if 75% of the value of the UK company is property.

International corporate tax is complicated and constantly changing at the moment so you really need proper advice, not reliance on a forum, particularly for forward looking planning.


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