For a UK non-dom, are dividends taxed if issued from an offshore company controlled in the UK

[babaorum]

If one:
- files taxes in the UK as a non-dom
- has a company in an offshore tax-haven
- the company is controlled by him so the company's profits are taxed in the UK at 19%
- the company issues him dividends paid into an foreign account

Will the dividend be considered foreign-sourced and not be taxed
OR
UK-sourced because despite the company being abroad it is UK-controlled and taxed, and so the dividends will be taxed as well?

 

[Martin Everson]

babaorum said:
UK-sourced because despite the company being abroad it is UK-controlled and taxed, and so the dividends will be taxed as well?
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Yes

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Please note my posts should not be taken as financial or tax advice. Please seek professional advice in that respect.

 

[babaorum]

Martin Everson said:
Yes
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Do you have a source? I couldn't find any HMRC guidance on this.

 

[CaptK]

You run the company from UK and are actively managing it therefore your non dom structure is useless.

 

[wheelspin]

Is there a tax liability if the company would be held by a trust or foundation? Do the CFC rules kick in?

 

[Martin Everson]

babaorum said:
Do you have a source? I couldn't find any HMRC guidance on this.
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Pay a tax advisor to tell you what I just told you perhaps.

wheelspin said:
Is there a tax liability if the company would be held by a trust or foundation? Do the CFC rules kick in?
Click to expand...

Depends on if you have UK sourced income.

You can always call HMRC's trust helpline and explain that you are a non-dom.

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Please note my posts should not be taken as financial or tax advice. Please seek professional advice in that respect.