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Where Taxpayers and Advisers Meet

DIVIDEND INCOME STRUCTURE

AF
Posts:2
Joined:Sat Jan 08, 2022 12:50 am
DIVIDEND INCOME STRUCTURE

Postby AF » Sat Jan 08, 2022 1:06 am

Hello,

Which of these below would render best tax-efficiency returns (i.e. minimal tax) on director's dividend payments viz:

a. Dividend payments to me, as Director of Single UK Holding company, that then uses different UK-SPV subsidiaries to acquire different UK SMEs shareholdings over time (i.e. all UK 3-layer structure)

b. Dividend payments to me, as Director of Single UK Holding company, that then uses different Jersey (or otherwise offshore) SPV subsidiaries to acquire different UK SMEs shareholdings over time (i.e. UK-Offshore-UK structure)

c. Dividend payments to me, as Director of Single Jersey Holding company, that then uses different UK- SPV companies to acquire different UK-SMEs shareholdings over time (i.e. Offshore-UK-UK)

d. Dividend payments to me, as Director of Single Jersey Holding company, that then uses different Jersey (or otherwise Offshore) SPV companies to acquire different UK-SMEs shareholdings over time (i.e. Offshore-Offshore-UK)

Whichever way, the target SMEs will be UK-based, whilst the SPV/Holding Co layers structure for Tax efficiency is the advice needed, from best-option/most tax-efficient perspective.

Look forward to your response soonest.

Many Thanks in advance

bd6759
Posts:3745
Joined:Sat Feb 01, 2014 3:26 pm

Re: DIVIDEND INCOME STRUCTURE

Postby bd6759 » Sat Jan 08, 2022 11:09 am

A directors doesn’t get dividends unless they are also a participator.

You don’t say where you are resident, but most of those structures will have a similar outcome.

robbob
Posts:3210
Joined:Wed Aug 06, 2008 4:01 pm

Re: DIVIDEND INCOME STRUCTURE

Postby robbob » Sat Jan 08, 2022 11:21 am

If you are bog standard uk residnet taxpayer its highly lilkely they will all be the same - even bog standard uk company does not deduct tax from dividends , hard to get much better than that situation - i would guess any tax efficient company structure you would use would "probably" be the same.
Things would probably only change if tax was witheld from non uk dividends.

as bd6759 rightly advised being a director doesnt automatically mean you will have dividend income - i am presuming you will have shares in the relevant company.

AF
Posts:2
Joined:Sat Jan 08, 2022 12:50 am

Re: DIVIDEND INCOME STRUCTURE

Postby AF » Sun Jan 09, 2022 5:11 am

Oh apologies if incomplete info.

Yea it's UK resident, thinking of having shares in "A" Holdings, with subsidiaries A1, A2, A3, ... etc as SPVs - to own acquired UK-based SMEs viz B1, B2, B3, etc.

Just wondering which of the configurations earlier listed above saves more tax on dividend payment from "A" Holdings to UK resident.

Is it a, b, c, or d configuration?

Thanks


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