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  1. Replies
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    Decent skewering of the deal here, Truss looks...

    Decent skewering of the deal here, Truss looks about as happy as Johnson/Gove the morning after the Ref; https://twitter.com/EmilyThornberry/status/1331920701171888133?s=20
  2. I agree it's unlikely, but the ECJ ruling that...

    I agree it's unlikely, but the ECJ ruling that Britain could unilaterally revoke Article 50 was also unlikely, a bombshell. There are crazier ideas than that those who have actually exercised their...
  3. Loss of EU citizenship referred to the ECJ

    There have been a number of court cases, but this is the first that has been referred to the ECJ. It particularly concerns those who exercised their freedom of movement rights (i.e. moved to an EU...
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    It’s a tiny bit more nuanced than this. The...

    It’s a tiny bit more nuanced than this. The Withdrawal Agreement in every way is a special case because of reciprocity. If the UK home office conspicuously declines to register EU nationals trying to...
  5. I took professional advice on this. It’s the...

    I took professional advice on this. It’s the temporary non-residence that’s the peril. After all, what tax advantage is being derived? You are not paying UK tax because you are not UK tax resident....
  6. I see what you mean. But there is no tax...

    I see what you mean. But there is no tax liability (unless one is foolish enough to be caught by temporary non-residence, in which case all bets are off), so nothing can be lowered.

    I.e....
  7. If you’re not tax resident and liquidate a...

    If you’re not tax resident and liquidate a company, you wouldn’t be eligible for BADR. But you also wouldn’t pay CGT because you’re not tax resident. You could therefore open the same kind of company...
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    As long as you don’t try and move back within 5...

    As long as you don’t try and move back within 5 UK tax years, yes.
  9. Replies
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    Correct. Or an EU citizen in the UK, as the whole...

    Correct. Or an EU citizen in the UK, as the whole point is the reciprocity of the arrangement.
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    Presumably this risk can be mitigated by having...

    Presumably this risk can be mitigated by having them do the bare minimum possible, and the accountant taking most of the slack?
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    Nope. If you're referring to the internal market...

    Nope. If you're referring to the internal market bill it doesn't affect citizens' rights.

    Citizens' rights feel reasonably secure on the basis that it would be mutually assured destruction.
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    It's a reasonable concern. I'd say it's a...

    It's a reasonable concern.

    I'd say it's a trade-off. For those roles which are deemed outside IR35, the fact that I am abroad bolsters the case.

    It will be easier to work and trade in Europe...
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    Doesn't this rather ignore the fact that the...

    Doesn't this rather ignore the fact that the effect of the advice is to pay HMRC more tax than would otherwise be the case? Issues are more likely to come from abroad if anything.
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    This seems like common sense, and is what most...

    This seems like common sense, and is what most contractor accountants (usually not cross-border experts) will tell you -- until you consider treaty non-residence. E.g.
    INTM120210 - International...
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    Yes, it depends on the purpose. Nevertheless,...

    Yes, it depends on the purpose. Nevertheless, without a director in the UK, and if the only director is tax resident abroad, the company is usually caught by treaty non-residence, so it is a first...
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    Generally agreed, but Lance and Malvolio and...

    Generally agreed, but Lance and Malvolio and another pm I got made it worth enduring the irrelevant torrent of abuse and disingenuousness from the usual.


    Sent from my iPhone using Contractor UK...
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    I think you’re rather sensitive, and you wilfully...

    I think you’re rather sensitive, and you wilfully mis-state my position into the bargain.

    I asked what other supplementary considerations may apply that were not within the scope of my paid...
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    Looking into this further, the point is more to...

    Looking into this further, the point is more to avoid signing contracts in the place you become tax resident. If you're on a brief trip in some place, and need to sign a contract quickly, this should...
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    Why do you feel compelled to post in order to...

    Why do you feel compelled to post in order to attack the premise of the question? F* off and post somewhere else.

    I provided my reason for posting in both places.

    Again. What are implications...
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    Nice try, but again, this is paid advice from an...

    Nice try, but again, this is paid advice from an international tax specialist with experience of winning cases.

    He advised that I should have an additional director in the UK, and ensure that all...
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    Also, I don't want the discussion to be derailed...

    Also, I don't want the discussion to be derailed once again by your incorrect understanding.

    Again, the topic is: what are subtle implications of having an additional director, not, as you want:...
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    Family member as additional director

    What implications are there to consider in making a family member an additional director?

    This is not being done for tax avoidance (they would not be paid or a shareholder unless to the minimum...
  23. Replies
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    Brexit happened at the end of January, but we are...

    Brexit happened at the end of January, but we are in a transition period. Thus in principle one can still move to an EU member state, and EU citizens to the UK, although it's not easy with Covid...
  24. Thread: Fight...

    by zerosum
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    Fight...

    Little evidence of this, sadly. The over promoted middle manager Frost remains in post.

    We can still expect the full cretinous assault of Brexit to devastate the country even more than it already...
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    What are you comparing to? This first wave...

    What are you comparing to? This first wave replaces the most portable machines.

    Apple are committed to doing an Apple silicon overhaul of the entire line within two years, but I’d wager we’re not...
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    You need to be legally resident in an EU country...

    You need to be legally resident in an EU country before the end of 2020. Each country varies in exactly what they require and how they administer the process. In some, it's sufficient simply to be...
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    Yeah...the new Macbook Air benchmarked higher on...

    Yeah...the new Macbook Air benchmarked higher on single-core and multi-core than the highest specced 16" Macbook Pro *without a fan* and with 15 hours+ battery life. Nuts.
    Apple Silicon M1 Chip in...
  28. It's not really "getting cash out of the UK...

    It's not really "getting cash out of the UK limited". Paying for someone's services on Upwork is akin to the relationship envisaged here. Of course, one may end up paying corp tax in the UK and in...
  29. I'm not sure why you see this as either/or. A...

    I'm not sure why you see this as either/or.

    A UK company is an incredibly useful option to 'keep agents happy'.

    But moving my personal tax residence abroad while keeping the LTD co would cause...
  30. Thanks, WordIsBond. These are complicated issues...

    Thanks, WordIsBond. These are complicated issues so while I haven’t totally appreciated the tone, I do realise there are many ways to get into trouble, so I’m tempted to join in the fun and perform a...
  31. Indeed. This is of course not about lowering tax,...

    Indeed. This is of course not about lowering tax, fraud, sneaking around in Spain while one is actually in Southampton or vice-versa, as so many here have lazily assumed/projected (uk corp tax...
  32. Cheers for the discussion, I'm out.

    Cheers for the discussion, I'm out.
  33. Perhaps it's easier if I say, for the sake of...

    Perhaps it's easier if I say, for the sake of argument, I'm completely mistaken. Exit tax does not apply to my situation. The various specialists I spoke to were blowing smoke up my ***.
    ...
  34. I agree, it's a good point, and it's something I...

    I agree, it's a good point, and it's something I dealt with. But what the hell has it got to do with exit tax?
  35. I asked about whether anyone had experience with...

    I asked about whether anyone had experience with situations where exit tax might arise and how they handled that.

    The only situation in which the '20 questions game' comes up is if someone doubts...
  36. Sure, I'm aware of this. Knowing this issue was...

    Sure, I'm aware of this. Knowing this issue was impending, I have asked each and every client I've worked with since Brexit whether they would be willing to work with an EU-based company instead...
  37. This is not possible. If I am the director and...

    This is not possible. If I am the director and only shareholder, then by virtue of my tax residency moving overseas, the company's residence does also.

    INTM120030 - International Manual - HMRC...
  38. No it made the most sense to me to give him only...

    No it made the most sense to me to give him only the barest idea. Most of the conversation was spent talking about my holiday home. :eyes
  39. INTM120070 - International Manual - HMRC internal...

    INTM120070 - International Manual - HMRC internal manual - GOV.UK

    DTAs always override domestic laws.
  40. Most UK accountants, particularly the ones...

    Most UK accountants, particularly the ones recommended around here, do not have cross-border expertise.

    Is it allowed to have a UK company with non-resident directors? Yes. The issue (per this...
  41. I'm sure it gave you some satisfaction to write...

    I'm sure it gave you some satisfaction to write this post, but there are a few logical problems that follow. If what you wrote were *absolutely* correct, without any possibility of nuance (i)...
  42. Yes Yes Can be controlled. The probability is...

    Yes
    Yes
    Can be controlled. The probability is that I would set up a foreignCo and bill the UkCo for work performed.



    Sent from my iPhone using Contractor UK Forum
  43. Ideally, at least for a few months. My...

    Ideally, at least for a few months.

    My understanding is that I need a decisive break with the UK (like taking a job or apartment abroad). That has not yet happened. I could very deliberately...
  44. Agree, but one of the potential advantages of a...

    Agree, but one of the potential advantages of a forum like this is to hear from people who may have grappled with such issues in the past.
  45. The main director and shareholder who...

    The main director and shareholder who incorporated it. Although other mechanisms could be considered.
  46. Moving away from the UK, leaving UK LTD open, and exit tax

    Has anyone dealt with moving away from the UK (becoming tax-resident abroad) but leaving their UK LTD open?

    With most DTAs, if the company doesn't have other directors/shareholders, this can lead...
  47. If the distribution happens once you're tax...

    If the distribution happens once you're tax resident elsewhere, the 10% would not be applicable because it's a UK relief. You'll pay capital gains according to where you're tax resident, in some...
  48. Replies
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    Just an illustration. Have a look into the arm's...

    Just an illustration. Have a look into the arm's length principle and transfer pricing, and base your research on your intended setup and people's experience with the same.
  49. To answer my own question, it seems that if one...

    To answer my own question, it seems that if one liquidates a company while non-resident and one suspects one may return to the UK within 5 years (or there are circumstances which could make an...
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    There are countries which will issue you with a...

    There are countries which will issue you with a tax residence certificate based on very few days indeed. But if you spent e.g. 60 days in that tax base and 150 days in a country with an aggressive...
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