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Where Taxpayers and Advisers Meet

Ltd co owner, dividends & going overseas...

johnuk
Posts: 8
Joined: Tue Dec 20, 2016 5:19 pm

Ltd co owner, dividends & going overseas...

Postby johnuk » Thu Jun 01, 2017 11:46 pm

I am currently domiciled and resident in the Uk and a 100% owner of a limited company in England from which I derive my sole income by way of dividends. I am considering becoming non resident and basing myself somewhere more tax efficient and continue to receive dividends.
I haven't decided where to go yet but I am aware there are a number of countries which would only tax me on income if it is brought into the country concerned. My understand is that no income tax would be payable on those dividends in the UK. So in theory assuming no income is brought into the new country there would be no personal tax to pay anywhere.
My question is regarding double taxation treaties. I have not taken any professional advice yet apart from a few fairly casual conversations on the matter, but there was some suggestion that these treaties may throw a spanner in the works and tax would be payable in one of the countries. Can anyone tell me if that is indeed the case and if so why ?

AGoodman
Posts: 1088
Joined: Fri May 16, 2014 3:47 pm

Re: Ltd co owner, dividends & going overseas...

Postby AGoodman » Fri Jun 02, 2017 10:42 am

It would be much easier if you could mention specific countries but you appear to be describing the remittance basis so possibly Malta?

I am not aware of double tax treaties ever imposing tax if none would be payable otherwise - they are generally either permissive or restrictive - allowing a particular country to levy taxes or preventing them from doing so.

Some treaties with the UK contain provisions preventing the other country from imposing tax but contain an exception where the taxpayer is under the remittance basis in the UK and so no actual UK tax is charged. I wouldn't have thought this was relevant to your situation.

Switzerland may be more complicated as a result of other bilateral agreements.

johnuk
Posts: 8
Joined: Tue Dec 20, 2016 5:19 pm

Re: Ltd co owner, dividends & going overseas...

Postby johnuk » Sat Jun 03, 2017 10:46 am

Thanks for your reply. Malta was indeed one of the places I have looked at and held brief conversations with a number of "professionals" there about this issue. Some told me that my plan was perfectly feasible and a minimum of tax would be payable which would not be affected by any tax treaty. However others including one of the large accounting firms suggested the DTA between Malta and the UK would mean income tax would have to be paid in one of the countries. I'm inclined to believe the former but nevertheless there is some confusion and I was surprised by their differing responses.
Another country I am looking at is Thailand, can you offer any comments about that ?


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