Reply to: Tax treaty question - Where do I pay tax?

[ASB]

I do not believe that expert advice is the only way that a person can/should gain evidence to form an opinion on an accountancy related issue.

I think that is very true. The OP has solicited a number of views. They range. These may help him get some of the issues clear in his mind. Possibly to the extent of thinking "it's a non starter" or possibly to the extent of being arguably better informed when/if he solicits proper professional advice - and it won't be cheap.

When it comes to international issues to do it right is complex (I never really bothered TBH, just did my own thing and hoped for the best really). It is even more complex, and important to get right, when skirting round the margins with structures that are designed to keep taxation to a bare minimum.

It is doable for the corporate to legitimately accrue profits in a zero/low tax environment. The two main issues to contend with are actually getting hold of that without suffering personal taxation somewhere and structuring affairs in such a way as those funds not being chargeable to tax where generated in the first place.

For an individual, even fairly well paid ones, the costs of advice, structure, being tied up in investigations etc for years - on my risk/reward scale - easily outweigh the benefits.

But, the OP is non-dom in the UK (whether he pays the remittance basis fee is unknown). Also he was talking about generation of significant profits from an ecommerce operation. This is a different case to the majority on here and he may be able to something and the benefits may potentially make the risk and costs worthwhile for them.

[Boo]

But sometimes, as in this case, seeking expert advice really is the only answer.

I do not believe that expert advice is the only way that a person can/should gain evidence to form an opinion on an accountancy related issue. Otherwise what is the point of this forum in the first place ?

You also ignore the fact that an accountant's opinion costs money and the OP may not have any intention of actually pursuing the course s/he is asking about but is just curions to know why a course of action is/is not possible or advisable.

This forum seems to me to be an ideal place to seek such information and the common blanket advise to speak to an accountant is out of place and obstructive. It is notable that the same people who post that advise also often post the canard that a forumite is not cut out to be a contrator or that a poster is caught by IR35 (usually on scant evidence and often irrelevant to the issue at hand).

Others have also posted that they find this behaviour irritating but my main point is that I can see no reason for it at all ?

Boo

[Boo]

And I've no idea why people persist in posting complaints about various aspects of this site on threads that are nothing to do with their perceived issue. It adds no value. If you want to complain - take it to General. If you object to a specific post, you can always use the "report post" button.

The issue is that people continually post replies that suggest that questions relating to accountancy are not valid on this forum. This is the accountancy forum and so a criticism of such replies is valid here in my opinion.

Boo

[NotAllThere]

This is an excellent question and I have absolutely no idea why people persist in using this forum whose only contribution is to tell people to not as questions here.

Boo

And I've no idea why people persist in posting complaints about various aspects of this site on threads that are nothing to do with their perceived issue. It adds no value. If you want to complain - take it to General. If you object to a specific post, you can always use the "report post" button.

[Alan @ BroomeAffinity]

This is an excellent question and I have absolutely no idea why people persist in using this forum whose only contribution is to tell people to not as questions here.

Boo

But sometimes, as in this case, seeking expert advice really is the only answer.

[Boo]

Why even have a forum called "Accounting / Legal" if all accounting questions must be asked to your accountant?

This is an excellent question and I have absolutely no idea why people persist in using this forum whose only contribution is to tell people to not as questions here.

Boo

[ASB]

With respect (yes, really) it's neither quite simple or straightforward. Starbucks, Facebook, Google have a battery farm full of accountants, tax lawyers and other experts all over the world and even they can't get it right.

As Louise stated above regardless of the country of incorporation, many jurisdictions tax profits where they are generated.

And you must have some tax bill if you think opening companies all over the world is going to be tax efficient. Zero (or low) tax jurisdictions typically have really expensive corporate managements structures.

Relax, forget your idea, and pay your tax.

The question is simple and straightforward.

It is the answer that is hugely complex; dependant upon the countries involved; the type of business; aload of other factors.

One point not mentioned. Where a typical one man band is operating will often tend to be regarded as resident for that period since that is obviously where it is controlled from. The fact that the dirctor is resident elsewhere is largely irrelevant. Though this may have heen what louisa meant when she mentioned permanent establishment.

[Alan @ BroomeAffinity]

And also, the last question you asked was about IOM companies. You were advised against it and you you'd be doing it "regardless". Guess that didn't work out too well. But still, if you're going to ignore advice why should we give a toss?

[Alan @ BroomeAffinity]

Louisa, not Louise. Apologies.

[Alan @ BroomeAffinity]

It's quite a simple and straight forward question so thought perhaps somebody knew. Doesn't mean I would rely on the advice, but it could make for a good starting point for further investigation.

Why even have a forum called "Accounting / Legal" if all accounting questions must be asked to your accountant?

With respect (yes, really) it's neither quite simple or straightforward. Starbucks, Facebook, Google have a battery farm full of accountants, tax lawyers and other experts all over the world and even they can't get it right.

As Louise stated above regardless of the country of incorporation, many jurisdictions tax profits where they are generated.

And you must have some tax bill if you think opening companies all over the world is going to be tax efficient. Zero (or low) tax jurisdictions typically have really expensive corporate managements structures.

Relax, forget your idea, and pay your tax.

[Louisa@InTouch]

The company will be deemed to likely have a permanent establishment in each of the countries and so be at risk to all the individual country taxes.

The country in which it is incorporated would still consider its position and they would do a whole load of technical examination before they gave up the tax they wanted!

[SueEllen]

It's quite a simple and straight forward question so thought perhaps somebody knew. Doesn't mean I would rely on the advice, but it could make for a good starting point for further investigation.

Why even have a forum called "Accounting / Legal" if all accounting questions must be asked to your accountant?

The accounting questions on here are related to being wholly in the UK tax system this is why the site is called contractoruk

Some of us have contracted or worked abroad so we can answer and direct people to other sources of information in relation to those countries, but no one here is able to answer complex questions about various random tax regimes.

[LordCharles]

Yes. The best approach with complex international tax strategies is to seek free advice on an Internet forum rather than seek professional advice. Crack on, what could go wrong?

It's quite a simple and straight forward question so thought perhaps somebody knew. Doesn't mean I would rely on the advice, but it could make for a good starting point for further investigation.

Why even have a forum called "Accounting / Legal" if all accounting questions must be asked to your accountant?

[Alan @ BroomeAffinity]

Yes. The best approach with complex international tax strategies is to seek free advice on an Internet forum rather than seek professional advice. Crack on, what could go wrong?

[WTFH]

Why don't you explain your question with some context, as it is you just sound like an idiot.

Lord Charles used to be a dummy who was operated by a human.

Charles, who currently does your taxes for you?