UK Fact-File Part 4:
Individual Business Tax-Efficient Structures
4.2 UK Individual Business for Non-Residents
Business possibilities for non-residents
It is possible for an incorporated company
to be non-resident in the UK and conduct significant business
there, but it must register for the taxes in the UK which
apply to it (Corporate income tax, VAT if turnover is above
the registration threshold, etc).
Where a company is deemed to be non-resident, it will be
liable to pay income tax on any income arising in the UK,
but generally not on its worldwide income. Maintaining non-residence
means not creating a permanent establishment, and not falling
under any of the tests which HMRC applies regarding management
and control.
With regard to the situation for an unincorporated individual
seeking non-residence in the UK and still conduct significant
business there, the situation is similar – as long as the
appropriate taxes are registered for in the UK with regard
to the business, non-residence can be maintained fairly easily,
although UK-sourced income will still attract taxation.
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