UK Ltd and Antigua Digital Nomad Scheme

[Barney2201]

Just wanted to throw this out to the forum to see if anyone can see any issues with this set up....

Planning to move to Antigua, initially on 2 year Digital Nomad visa then purchase property to stay long term.

Own a UK Ltd company, we are planning to put all share holding in wife's name (she is currently FD) and make her the CEO

she will reside in Antigua permanently whilst I commute every few weeks back to London staying under the 90 midnights.

We pay my wife a high salary plus bonus and I get nominal wage.

There is no personal tax in Antigua and UK HMRC could not tax the salary as non resident therefore we ”˜should”˜ be able to remove most company profit before paying Corp tax, leaving a small profit at end of year to keep HMRC happy.

Numbers involved are around £1.5 million turnover of UK Ltd, gross profit of around £400k, pay my salary of £30k which I pay tax on days worked in UK then £350K a year salary and bonus paid tax free to CEO in Antigua, leaving £20K profit in company which will be subject to Corp tax.

Can anyone see any holes in this plan?

 

[Sols]

You're both probably not interesting to HMRC for personal tax, although you're playing with fire by being in the UK and doing work there.

The company remains tax resident in UK by being incorporated as a UK company and be required to pay UK corporate income tax. Additionally, the company might become tax resident in Antigua. In a worst case scenario, you will need to file and pay taxes in both countries. There is a DTA between UK and Antigua, so you shouldn't have to pay more than 25% total.

Since you have business activities within Antigua, I'm not sure an IBC would work in this case.

In this type of setup, I'd consider a middle-tier jurisdiction like Isle of Man instead with local professional directors.

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This is the probably the answer to your question.

 

[Barney2201]

Thanks for the info.

Fully aware the UK company would be subject to Corp tax but plan is to remove most taxable profit from UK company by way of salary / bonus payment direct to Antigua director therefore our declared UK Corp tax bill should be minimal.

Might still be safer to use middle tier, we are currently based in Guernsey so might leave our current setup in place or look into Antiguan IBC

 

[PaulKruger]

Barney2201 said:
Might still be safer to use middle tier, we are currently based in Guernsey so might leave our current setup in place or look into Antiguan IBC
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what make you consider to relocate from Guernseye to anywhere else, do you pay any tax at all?

 

[uplana]

PaulKruger said:
what make you consider to relocate from Guernseye to anywhere else, do you pay any tax at all?
Click to expand...

valid question thinking about the same ?

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[Barney2201]

Originally moved to Guernsey to zero our uk Corp tax bill. This worked well, plus Guernsey has a 20% personal tax cap, however... you end up paying about 13% in national insurance and the biggest problem is housing. There are two housing markets, local and open, you can only live in local if you were born in Guernsey or you have a permit which comes with a job. We live in the open market which was limited but ok until COVID now half of London has decided they can work from home and everyone wants to come to Channel Islands as only 30min flight back to Gatwick. Property prices have gone up 15% in last 6 months. A 3 bedroom semi-detached house is now £1 million+ and you still need to renovate. General cost of living is also more than UK. Hence we are looking at the move to Antigua and zero personal tax.

 

[PaulKruger]

Barney2201 said:
General cost of living is also more than UK. Hence we are looking at the move to Antigua and zero personal tax.
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don't you want to speak with some local CPA or lawfirm that can help?