Corporate Residence

[tha1_n]

Hi I have a client who has 100% of shares in a foreign company.

The client is UK resident deemed domicile and I understand that the company would fall within the UK tax regime under the DTT if decision making was made in the UK. Could the client get around this by going abroad to make decisions??

Thanks in advance.

[SteLacca]

If this is a sole director/shareholder company and the director remains resident in the UK, probably not.

If the director moves abroad permanently (such that they become non-resident), yes.

If there's an overseas director and all decisions are taken there, possibly.

Whether it's worthwhile will depend on where, and the terms of the DTT.