Hi
I have a client who is a non resident, who has a company registered in the UK. They only have dividend income from UK sources.
From my reading it is my understanding that there is two options here :-
1/- Claim the personal allowance & have UK income taxed at appropriate rates.
2/- Don't claim the personal allowance & instead the investment income (dividends) will be treated as disregarded income & it would therefore not be taxable at any level of dividends declared.
Option 2 however does not apply to investment income connected to a trade in the UK through a permanent establishment.
My questions are :-
1/- Does the fact it is their own company affect the above options in anyway
2/- Would they fall under the permanent establishment caveat. I don't believe they would, as they are not just a UK resident company because of this fact, the company is actually a UK registered company as previously stated.
Thanks
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