Structure for UK resident
- Thread starter iniwanginwg
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I am not perfectly sure what you are asking but I'll try to answer anyway:
If you have a local director than the place of management & control issues don't arise. By issues I mean that if the place of management and contorl stays in the UK that would give the HMRC an oppurtunity to consider the hungarian company a UK tax resident based on the OECD double tax treaty between the two countries. This is what the local︀ director avoids. The company stays a hungarian tax resident with 9% tax.
In the above︁ solution if the OP still is the stakeholder of the hungarian company he still has︂ to pay dividend tax normally (as described in the double tax treaty) as he does︃ now in the UK. So he can only capitalize on the 9% Hungary corporate tax︄ rate vs 19% UK tax rate (note the OP said 20% in the first post︅ for some reason). However that is quite signifficant regarding the mentioned 1M GBP/month and the︆ income lands in his name in the end.
In the other example where the OP︇ would direct the profits through a passthrough taxed LLP the income would land in the︈ hands of the nominee shareholder who is resident in the 0% tax country on paper︉ not in the hands of the OP. This obviously further complicates things. Some people have︊ no problem with the money not being in their name, some others solve this with︋ a trust deed or a loan. This was what I called trickery. And this was︌ the part that is not needed in the hungarian company solution.
I am new here︍ and I can not send PMs yet (my bad, haven't taken the time to read︎ how they work on this forum yet). I'm going to assume you can, so if️ something is not clear or I haven't answered your question completely feel free to send me one.
If you have a local director than the place of management & control issues don't arise. By issues I mean that if the place of management and contorl stays in the UK that would give the HMRC an oppurtunity to consider the hungarian company a UK tax resident based on the OECD double tax treaty between the two countries. This is what the local︀ director avoids. The company stays a hungarian tax resident with 9% tax.
In the above︁ solution if the OP still is the stakeholder of the hungarian company he still has︂ to pay dividend tax normally (as described in the double tax treaty) as he does︃ now in the UK. So he can only capitalize on the 9% Hungary corporate tax︄ rate vs 19% UK tax rate (note the OP said 20% in the first post︅ for some reason). However that is quite signifficant regarding the mentioned 1M GBP/month and the︆ income lands in his name in the end.
In the other example where the OP︇ would direct the profits through a passthrough taxed LLP the income would land in the︈ hands of the nominee shareholder who is resident in the 0% tax country on paper︉ not in the hands of the OP. This obviously further complicates things. Some people have︊ no problem with the money not being in their name, some others solve this with︋ a trust deed or a loan. This was what I called trickery. And this was︌ the part that is not needed in the hungarian company solution.
I am new here︍ and I can not send PMs yet (my bad, haven't taken the time to read︎ how they work on this forum yet). I'm going to assume you can, so if️ something is not clear or I haven't answered your question completely feel free to send me one.
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