Stick with Sark or move on???

Barney2201

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Feb 19, 2017
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Looking for some ideas on my next move.......

The background.... UK national, moved to Guernsey from UK in March 2019. Pre-Covid we had a successful events company with a turnover around £1.3m and a net of around £300K, Covid killed the business dead. Restarted in June 2021 and business has been very good. First year (only 10 months trading after Covid reopening) £2 million turnover and £600K profit, this year on target for £3 million with a £800K - £1 million net and next year we hope to achieve £4 million turnover. (all figures before taxes).

As the business is mainly a service company we don't own or purchase much asset, we hire all equipment and staff for all events. The business is a UK business.

Moved to Guernsey as we were starting to get slammed on UK corp tax and personal tax. Guernsey was good for Covid but.... It still has a 20% personal tax plus once you add in NI the true cost is closer to 30%, in addition we can only rent a house on the Open Market which is big money (anything decent £4K+ per month), to purchase £1 million plus minimum. Plus Guernsey is getting more and more expensive (flights, food etc)

Once the business started making money we decided to make a leap across the water to Sark (no personal income tax), lived on the island from November 2021 - March 2022), rented a holiday home for the winter, but by the quirks of Sark you get a 1 year lease. So when we had to leave due to the summer season we did some time in Mauritius and South Africa.

When the lease finished in November last year I rented a small cottage on the island to keep the tax status.

From a corporate perspective, the original plan was to have a company in Guernsey which extracts profits from UK to Guernsey, however we never got the structure off the ground due to Covid. We decided to ditch the structure when we moved to Sark as Guernsey is now pretty hot on substance, both directors were Sark tax resident and we didn't;t have any form of substance on the island.

I'm now in a very confused situation, I am still Sark tax resident but with the amount of travel I do haven't spent any real time there since March last year. I have 'bounced' a lot recently between UK, Spain, South Africa... To be Sark tax resident you only need accommodation available to you for 90 nights, you don't have to actually live there. The wife now wants to live in Guernsey which she is doing and to be honest we will probably call it quits as we now want different things. Bouncing around the world for the last year has been a life changing experience and to be honest I'm not ready to call it a day any time soon.... I'm 46 so not young but not old....

So what next! I need to run the UK company, so I need to live in a time zone which is workable (+4hrs in Mauritius was a killer), also as I bounce in and out of the UK almost weekly something less than 2.5hrs flying time would be good. You can't set up a company in Sark but then there's no CFC rules. I do like the idea of living somewhere which I can call home (like beach and bit of a foodie) and I'm not looking to pay no tax just ideally a combined sub 10% corp / personal.

Do I stick with the Sark solution but don't spend any time there and constantly play the clock watch of midnights in foreign countries and not triggering tax or look at another solution? And if so what's the best solution. Malta and Cyprus really don't appeal as places to live.

Would consider Monaco but I am not asset rich so can't throw down £2 million to get a bank account....

Could I rent an apartment in Monaco but keep the Sark place and call Sark home for tax purposes (although I will need a French visa)? If Monaco wanted to try and call me tax resident then that would be fine. However this still doesn't answer the question of where to set up a new company to extract profit from the UK with substance. If it's in the same country I reside in then I can give it the substance by opening a design office employing a local or two and then charging a fee for every design to the UK company.

Some of the digital nomad schemes are interesting such as Croatia but then I still need to set up a company with substance somewhere for profit extraction.

If anyone knows or is a tax specialist with UK knowledge and would like to advise please get in touch....

Any thoughts most welcome, and if anyone is interested by Sark just drop me a message.
 
It seems that you don't dislike Sark. So you could buy a property there on the open market (with a £1m budget you should be fine), establish a solid presence on the island and enjoy traveling whenever you like without risking to be questioned about your residence. With the money you save on taxes you could buy a decent boat for your wife to travel to Guernsey.

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Guess the question is what is the risk of another country trying to tax me if I'm rarely on Sark..... The bouncing around the world game is fun but would still like a base....

As for liking Sark, that's a tough one. There is a strong sense of 'you're not from round here' mentality. It's a cold wet muddy rock in winter but pretty in summer (not Med sunny beach pretty). I spend 3 months in the UK which are all sporadic nights, commuting from Sark is difficult outside of season as ferries are limited and the weather can mean you're stuck, sometimes for a day or two.

Is there a better low tax deal out there which allows me to bounce in and out of London, establish a company in the same place and call it home.... Probably seeking the golden egg which everyone is after, but what's the real best option at the moment?

The only other solution I can think of is using one of the Digital Nomad schemes and stilling calling Sark home for tax (Croatia looks promising), however would have to be careful not to establish PE there..... Maybe a Dubai company with substance (guess I would need to talk to Fred) and a low tax Euro'ish personal solution.

Is Sark truly one of the best deals for Uk passport holders or when you balance quality of life and paying a little tax is there a bette option?
 
Don't mind +\- 2hrs but 4 for somewhere like UAE is pretty tough to work. Good to know I'm probably already barking up the ”˜right tree'”¦.
 

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