Uk resident + Cyprus Company DTA

[Nanoo]

My question is, if i incorporate a Cyprus company as a UK resident i could use the DTA to pay only 12.5% of coporation tax in Cypris and prove to HMRC that i paid the tax in Cyprus to avoid paying them in UK as well?

Here's a example tell me if it's correct and legal.

1. UK resident.
Company in Cyprus.
100k$ profit in 2019 (kept in the cyprus corporate bank account).
12.5% to pay in Cyprus
0% to pay in UK

I think this thread will help multiple people to figure out the best use of the DTA for for uk resident.

 

[Nanoo]

Here's more details for example 1.
Company registered using nominee director + shareholder.
I will‌ manage the company from UK but it's a dropshipping business, no offices, wharehouse and no‍ income come from UK.
I will use only a laptop + Cyprus vps to manage⁠ the online business.

 

[happyjohn]

yes that's how this works. It's not difficult as long as︁ you have audited accounts and tax reports available for the company then it's possible.

 

[Juoffshore]

A company will be UK tax resident⁤ if it is incorporated in the UK. Additionally, for those companies not incorporated in the⁣ UK, they will be considered UK tax resident if they are centrally managed and controlled⁢ in the UK. Central management and control means the highest level of decision making and︀ not, for example, operational control, although clearly these can go hand in hand.

So in︁ this case if you get caught, HMRC, can challenge that your Cyrpus company could be︂ taxed as a UK one!

 

[JohnLocke]

Just want to‍ added, this is exactly as any other tcountry and ax office in Europe.

You need⁠ a very good and strong setup in Cyprus to avoid anyone questioning your operation.

 

[jackfrost]

Btw not in detail related but recent CFC ruling in one of the strictest jurisdictions‌ in Europe:

The German Federal Tax Court Limits German CFC Rules And Anti-Abuse Provisions To‍ Wholly Artificial Arrangements - Tax - European Union

Very nice details on what they did⁠ for "substance"