Switzerland Holding Company owning UK LTD, where to pay tax?

[clemens]

I maintain and run a dozen companies. One of our setups is a Switzerland Holding company that own 100% of the shares in the UK LTD - it is registered as a daughter company. How is it taxed, in Switzerland or in the UK ?

All activity goes out from Switzerland!

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[Marzio]

If the UK LTD is tax resident in UK then it pays UK corporate‍ tax.

 

[clemens]

How can it be tax resident in the UK if there is nothing there, everything‌ is controlled from Switzerland ?

 

[Marzio]

Where is the director resident?

UK LTD is considered tax resident‍ in UK in case of statutory seat and little substance.

 

[clemens]

Switzerland.

 

[Marzio]

You have to request a tax residency transfer and it has to be approved by‌ HMRC, then the UK LTD will be exempt from UK CIT

https://www.gov.uk/hmrc-internal-manuals/international-manual/intm120070#IDABC25

 

[clemens]

Thank you, will do that. Wasn't aware of the rules since I had‍ not the chance to ask our tax consultant about it.

 

[Onassis]

Where is this table‍ from?

 

[Marzio]

https://www.government.nl/binaries/...onduit-companies/PwC+comparative+analysis.pdf