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  1. #11

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    Quote Originally Posted by Jessica@WhiteFieldTax View Post
    Tedious but possible.
    Is the corp tax higher in UK or Latvia? You could keep the UK Ltd then create another in Latvia, then invoice yourself from the Latvian company and even pay yourself a salary from UK to Latvia without going through PAYE as it is Latvian's issue to sort out your income tax etc not UK's.

    Might be better if you keep half the money here half there? Whatever works for you and is most tax efficient. If you leave the UK make sure you also claim back any tax paid in the last 5 years. Talk to your accountant about this one, might get a nice lump sum cash but the catch is that you cannot return to the UK as a resident EVER!

    Might be worth talking to your accountant about this, could end up making quite a substantial saving moving money around.
    Last edited by Drei; 20th October 2016 at 23:07.

  2. #12

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    If I was the OP I would look seriously at incorporating in the Isle of Man or similar. If the client Co will deal with an IoM jurisdiction company, there could be big advantages regarding how you operate. Many companies appear to be trading as a UK company but when you look deeper they're IoM registered.

  3. #13

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    Quote Originally Posted by Fred Bloggs View Post
    If I was the OP I would look seriously at incorporating in the Isle of Man or similar. If the client Co will deal with an IoM jurisdiction company, there could be big advantages regarding how you operate. Many companies appear to be trading as a UK company but when you look deeper they're IoM registered.
    Correct - most betting companies are IoM or Channel Islands registered.
    The greatest trick the devil ever pulled was convincing the world that he didn't exist

  4. #14

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    Quote Originally Posted by Fred Bloggs View Post
    If the client Co will deal with an IoM jurisdiction company, there could be big advantages regarding how you operate. Many companies appear to be trading as a UK company but when you look deeper they're IoM registered.
    If this is true (and I'm not saying it isn't) then why do most of the loan schemes use a genuine UK company as the paypoint for the agency, before sending to IoM 'trust'?
    I suspect that most agents will refuse to pay money to an IoM registered company.

    IANAITA

  5. #15

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    Default Isn't it a case of a UK non-resident being charged on UK-based earnings?

    I have come across a number of discussions online which suggest that the HMRC regulations in terms of tax-residency are different to those of non-PSCs.

    Wouldn't it be likely that I would still have to pay UK tax on all my UK-based earnings as a UK non-resident who has UK-based earnings?

  6. #16
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    Quote Originally Posted by Fred Bloggs View Post
    If I was the OP I would look seriously at incorporating in the Isle of Man or similar. If the client Co will deal with an IoM jurisdiction company, there could be big advantages regarding how you operate. Many companies appear to be trading as a UK company but when you look deeper they're IoM registered.
    That would be fine. Though its taxing jurisdiction shouldn't change. It may be IoM, it may be Latvia. It could be both.

    The issue isn't so much getting the money in there, it's legitimately getting it out without it becoming subject to personal taxation

    The UK end may, of course, refuse to deal with an IoM company.

    A fairly common method is to set up in the UK owned by the IoM company and utilise licensing arrangements etc to migrate the turnover from the UK company as a cost to the IoM company as revenue under the licencing agreement.

    However it is very dependant upon the individuals exact circumstances and individual appropriate advice (which unless you are <insert name of US company here> may well cost more than any benefit that is obtainable.

  7. #17

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    Quote Originally Posted by deepblueuk View Post
    I have come across a number of discussions online which suggest that the HMRC regulations in terms of tax-residency are different to those of non-PSCs.
    Sorry, that makes no sense. Can you clarify.

    Quote Originally Posted by deepblueuk View Post
    Wouldn't it be likely that I would still have to pay UK tax on all my UK-based earnings as a UK non-resident who has UK-based earnings?
    If you are resident in Latvia then you won't have any UK earnings.

    Most likely, if you have a UK company both jurisdictions will want a tax return, both corporate and personal, and the relevant double taxation agreement will place taxing rights in the country of residence.

    However this is going to be fact based rather than principle based, and you will need to delve into the DTA and assess your situation against it.

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    Quote Originally Posted by LondonManc View Post
    Correct - most betting companies are IoM or Channel Islands registered.
    Quote Originally Posted by Fred Bloggs View Post
    If I was the OP I would look seriously at incorporating in the Isle of Man or similar. If the client Co will deal with an IoM jurisdiction company, there could be big advantages regarding how you operate. Many companies appear to be trading as a UK company but when you look deeper they're IoM registered.
    However there is a considerable difference between a betting company or a PLC and a one person company.

    The betting co/PLC will either:

    (a) do enough to have control in IOM/Channel Islands, eg an office there and board meetings there

    or

    (b) pay tax in UK on at least some of its profits - look at transfer pricing.

    Different kettle of fish to OP.

  9. #19
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    Quote Originally Posted by LondonManc View Post
    Correct - most betting companies are IoM or Channel Islands registered.
    There are historic reasons for that dating back to the speed in the mid 1990s that countries could handle the legal changes to allow betting on the internet - prior to that telegraphic betting was banned everywhere . Gibraltar, Alderney and a few Caribbean Islands (St Vincent) moved very quickly to try and capture the market with a combination of leeway and decent rule enforcement.
    merely at clientco for the entertainment

  10. #20
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    Quote Originally Posted by Jessica@WhiteFieldTax View Post
    However there is a considerable difference between a betting company or a PLC and a one person company.

    The betting co/PLC will either:

    (a) do enough to have control in IOM/Channel Islands, eg an office there and board meetings there

    or

    (b) pay tax in UK on at least some of its profits - look at transfer pricing.

    Different kettle of fish to OP.
    There are lots of restrictions on transfer pricing, and ipr transfer- which of course isnt news to you. I seem to recall a major evasion case centered around that involving a well known japanese car manufacturer.

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