Possible setup for UK LTD moving money to e.g. UAE

kermaster2022

New Member
May 3, 2022
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I'm after a little advice here, which might well be "don't do it you fool".

I'm a UK resident, about to open a new UK LTD, earning about £150k pa from other UK companies. For now, I need to remain resident in the UK, although this may change in a few years, and my clients will not accept invoices from non-UK companies and will only pay into UK bank details (EMI should be OK). My (HMRC declared) pay from the setup should be <= £50k in salary and dividends from UK or foreign sources. Now the tricky part: I want £50k or more to move abroad where it can be invested in shares and crypto with some kept as cash. I also want these assets to be protected from the child maintenance service here in the UK as they will likely decide that it's a diversion of income and include it in their calculations.

My thoughts so far:
A US LLC owns 20% of the UK LTD in class B shares, with me owning the other 80% in class A shares, making me the only PSC. The LLC has one member, being a freezone UAE company with a bit of substance (@Fred's setup perhaps). The UK LTD pays UK corp tax, then dividends based on share class, with £50k of dividends going to the LLC into an EMI account opened with a UAE residence card. The LLC then transfers this from Wise to a local UAE account, which then goes to IBRK, Naga, etc.

I'm hoping this avoids the UK CFC rules as (a) it's only £50k so should be excluded and (b) I'm lucky enough to have a 2nd nationality and TIN, which will be used for the UAE side, with no IRS registration on the US side. I'm more than happy if my old country (Australia) thinks I've moved to Dubai, but a lot less happy if they tell the UK about it as my name and DOB are the same on both passports. I'd rather avoid darks, but happy to use nominees if this would help in any way.

I know I'll need professional advice to progress further, but I'm just wondering if this setup seems doable or if anyone has any other suggestions.
 
A diagram of what I described above:
Untitled Diagram.drawio.webp
 
Few notes:
-Wise won't work with UAE address
-This will cost arm and a leg and the 20% you send will evaporate in fees
 
Payoneer perhaps then instead of Wise; there has to be one that will accept the UAE ID. Re the costs: in another thread, I read the UAE costs are €8k for year 1 and then €5k per year thereafter, plus costs for visa, bank, etc. Another thread mentioned US$11k for the UAE setup in total (not including the ongoings I guess), which again, doesn't seem that bad to me. A New Mexico LLC doesn't cost much, and the transfer fees shouldn't be that much either I don't think. Certainly covered in the £30k in the UK or £10k in UAE expenses. Maybe I've missed something very obvious, or my "little substance" confused things. I'm not meaning employees, local directors, etc, but just enough to get the bank account. If this needs an ejari as well to get things moving, I think that would be OK, unless I needed to keep paying it beyond the first 3 or 6 months.

It's not 20% that I'm looking to save: if I paid myself that extra £50k as a dividend I'd be paying an extra £33k in taxes and CM. Possibly I can leave it in the UK company, or invest in shares from there, but I then pay at least an extra £6k per year in CM, and I'd rather fork out £10k in fees TBH.
 

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