Any UK citizens on here with an IBC?

[robbie777]

For the long term I am thinking about setting up a company in Anguilla and‌ follow its citizenship by investment program and eventually become a permanent citizen on the island.‍ But at present I am a UK citizen paying UK taxes.

The questions I have⁠ is for any other UK citizens on this forum that already has an IBC in⁤ the caribbean. I don't have a LTD company in the UK and not looking to⁣ set up one either. I know I would have to fill out CT600B or CT600J⁢ if I had a UK ltd company with a subsidiary company abroad but If I︀ don't have a UK LTD I am unsure what forms I need to file. I︁ have tried contacting HMRC a dozen times and having no luck getting any reply from︂ them at all on the matter.

Knowing that the company is going to be in︃ Anguilla, it is not an exempt country on the list and has to pass through︄ a cfc gateway. Do anyone know what I have to file if I pay myself︅ from the Anguilla company? Would it still the the CT forms even though I do︆ not pass the profits through a LTD company or can I pay myself and only︇ mention it on the self assessment return?

Any helpful information from someone who is a︈ UK citizen and has an IBC would be greatly appreciated.

Or if anybody knows of︉ a UK accountancy that deals with offshore companies and UK tax that would also be︊ great.

 

[Martin Everson]

If your sat in UK then place of operation for an IBC would be where‌ the directors are resident hence UK. In general terms the offshore company will be transparent‍ to HMRC if you are the owner. Hence all income of offshore company distributed or⁠ not distributed and even where you could benefit from it WILL be attributed to you⁤ personally and taxed as such under personal income tax rates. UK has tough anti avoidance⁣ rules as you may know

P.S The place of operation of an IBC can never⁢ be in the country of incorporation by the very nature of an IBC being an︀ offshore company having to operate outside its country of incorporation.

I would seek professional tax︁ advice before proceeding.

 

[robbie777]

Thanks for replying.

There is also a LLC option in Anguilla but I am unsure‌ if the UK would see it as opaque as it does a US LLC. I‍ will have to look more into it.

 

[Fazoule]

@Martin Everson I see every this advice (good advice indeed) however I might have contacted‌ 20 UK chartered accounts and there wasn't even ONE that was capable of answering the‍ question of what tax to pay / what form to fill when having an IBC⁠ being a UK resident...

Would you be able to share a list of firms that⁤ would be able to help us in this regards? Or at least what kind of⁣ accountants we need to look for on Google (what kind of keywords?) ?

 

[robbie777]

I found these guys.. they are UK accountants that deal with offshore︀ companies and UK residents

https://www.taxinnovations.com/specialist-tax-planning/non-uk-structures/offshore-companies/

 

[CaptK]

HMRC will regard you as self employed and make you liable on profits.

 

[robbie777]

Problem being it will pass through the cfc gateway. Meaning I could‍ face corporation tax in my situation.

 

[CaptK]

You need to pick your poison because both are viable arguments. Choose one and go‌ down that road.

 

[Martin Everson]

Yup they are saying exactly what I said.‍ That for a UK permanent tax resident the offshore structure is transparent and offers nothing⁠ in terms of tax savings.

You will find very few tax accountants with proper cross border︀ structure experience outside of those that service High Net Worth Individuals. Most will now not︁ bother to help you due to the below. It will bring them nothing but trouble︂ to help the average joe.

https://www.offshorecorptalk.com/th...eporting-comes-into-effect-1-july-2020.29711/

 

[Martin Everson]

You need to examine HMRC's internal⁠ manuals. They see it as Opaque as they state below.

https://www.gov.uk/hmrc-internal-manuals/international-manual/intm180030

 

[robbie777]

Awesome .. thanks for this. HMRC manual‍ is so large it is like a maze.