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Recent content by zerosum
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Z
IR35 and not being tax-resident in the UK
On the positive side, I fail the first automatic test (<16 days for each of the last three tax years, indeed 0 for 20-21 and 21-22, have tried to keep all boarding passes and have access to receipts or invoices or rental slips for most nights abroad). Fwiw, I also had 0 ties per the SRT...- zerosum
- Post #16
- Forum: Business / Contracts
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Z
IR35 and not being tax-resident in the UK
Onboardings, periodic meet-and-greets, answering a few emails while visiting family in the UK...the line between incidental and not is not as clear as it could be. What would be a worst-case upshot here in your opinion?- zerosum
- Post #5
- Forum: Business / Contracts
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Z
IR35 and not being tax-resident in the UK
Yes, I should have clarified this point. Have had some discussions about inside-IR35 roles, but when I introduce the topic of not being UK-resident, needing to apply an NT tax code, and so on, discussions tend to dry up at that point.- zerosum
- Post #4
- Forum: Business / Contracts
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Z
IR35 and not being tax-resident in the UK
Just trying to clarify my understanding of one aspect of IR35 liability. As I’ve mentioned elsewhere, I’ve been non tax-resident in the UK for over 3 full tax years now, though I still have a UkCo (with one other Uk-based director) for the sake of contracting with UK-based clients. My...- zerosum
- Thread
- Replies: 23
- Forum: Business / Contracts
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Z
Subcontracting and NDAs
Makes sense. I presume you'd put the non-compete bits in the clear/simple contract?- zerosum
- Post #5
- Forum: Business / Contracts
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Z
Subcontracting and NDAs
I'm assuming that any confidentiality clauses in my contract with the agency have been passed down from the agency's contract with the end-client, so why not just repeat the same? And at the same time I can include the non-compete to avoid any risk of the subcontractor going and trying to do the...- zerosum
- Post #3
- Forum: Business / Contracts
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Z
Subcontracting and NDAs
My contract allows for subcontracting, provided confidentiality is maintained. I’m considering using this to screenshare and brainstorm on a few knotty issues, possibly hand over keys/access further down the line if I can carve a few self-contained bits out. Has anyone tackled NDAs/non-compete...- zerosum
- Thread
- Replies: 4
- Forum: Business / Contracts
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Z
Moved abroad, close UkCo now?
So in this scenario would you see either (a) holding onto the existing UkCo or (b) opening a new one in a few months as any more likely to prompt an investigation? Or much of a muchness...I suppose I'm thinking that while the large dividend is justified on the basis of my new residency, it is... -
Z
Moved abroad, close UkCo now?
One clarification: I have withdrawn all profits as dividends. So when I close the company it will be without a liquidator. I am not UK tax resident (haven't set foot in the UK for well over two years, don't own property, minimal ties) and therefore I don't believe I would have been eligible to... -
Z
Moved abroad, close UkCo now?
Very useful, thanks. Can you say more? -
Z
Moved abroad, close UkCo now?
As I mentioned, I think we should just agree to disagree. You're welcome to your earlier opinion, as I am to mine. I reserve my right not to share my paid advice publicly for reasons of privacy but the invitation by PM stands. For the purposes of my earlier question, let's just say you're right... -
Z
Moved abroad, close UkCo now?
If a DTA specifically gives taxing rights to a country in which you are tax resident at the time when you make the relevant distribution, the UK does not get the right to tax it again, despite the 5-year disregarded income clause to which you refer. There is a categorical exemption. So if you... -
Z
Moved abroad, close UkCo now?
...unless there is a DTA with the UK which gives taxing rights on dividends to the adopted country (there is). -
Z
Moved abroad, close UkCo now?
I've moved away from the UK. 2y now (measured in tax residence). I still have a UK company. Have withdrawn almost all funds as dividends. The DTA between the UK and my new country gives taxing rights on dividends to the new country. (Took paid advice to go over the SATR and ensure this would... -
Z
Delay in signing a contract
Have a signed contract and schedule from the agency. Had already begun work, as there was quite a bit of to-ing and fro-ing on one or two clauses. Can there be any issues with a delay in signing on my side? The agency seems to have forgotten.- zerosum
- Thread
- Replies: 3
- Forum: Business / Contracts
