Originally posted by Wanderer
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But this doesn't make all the problems go away by any means. You covered some of them, but a few others spring to mind
- Is the OP themselves resident in the UK. Remember it is entirely possible to be resident in more than one place at once.
- Is MyCo Madeira at risk of becoming UK resident due to it's centre of economic interest and where it is controlled from.
- Is the common ownership of MyCo UK and MyCo maderia such as one will be treated as a branch.
- If the OP did not own MyCo UK would they still be regarded as controlling it
- What is the impact of the DTA between the UK and Portugal (as far as it covers Madeira which has special status) on both corporate income and personal income
- Would the 20% Portuguese withholding tax still apply on the services nominally exported via any UK entity involved
Ultimately if the OP is genuinely resident in Madeira and avoids becoming resident in the UK then they may be able to save a few quid, but it will depend very much on the individual circumstances - as it always does.
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Welcome
I'm not a UK national either and I looked into the possibilities a while back. The problems you have to overcome are:
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