Non resident UK Ltd with Cyprus shareholder/management

[Mws]

Hello Offshore Talk Community,

As an Cyprus resident with an UK Ltd (managed from Cyprus), would the Ltd be taxed in Cyprus because of cfc/pe and tax treaties? (Customers are outside UK.)

Thanks a lot!

Last edited: Dec 31, 2020

 

[Sols]

It would start out as being tax resident in both. Tax resident in UK by being incorporated there and tax resident in Cyprus by being managed there. However, then you'll have to leverage the tax treaty to determine if you can get the company to qualify as treaty non-resident in UK making it tax resident only in Cyprus.

To what degree this is possible depends on the nature and structure of your business. Read up on the relevant agreements and have a chat with a tax adviser about that.

At the end of the day, it'd probably be a lot easier to just use a Cypriot company unless there's some reason you absolutely have to have a UK company.

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This is the probably the answer to your question.

 

[Jerry1911]

Is it possible to combine non-dom residency with such structure? It's easier to get a bank account with a UK company.