"Offshoring"

Author
Discussion

macron

Original Poster:

11,576 posts

179 months

Wednesday 21st May
quotequote all
There have been similar threads but with little detail, and having spent a few hours in the Glaswegian sun today with someone who is doing it, I wondered if the accounting cognoscenti would like to immediately find flaw with this as it sounds far too good to be true to me:

-IT consultant and wife making a killing through a conventional Ltd co, usual service provider where it's your time exchanged for money, very few overheads, rates of 15-1800/ day
-After some sort of webinar, pays to establish a new Ltd in Gibraltar. A "Non Resident Company".
-Initial invoices are now to Gib. None of the payors care, it's just new bank details.
-0% corp tax on income not derived from Gibraltar with one of these structures.
-Small invoices to the Gib co from existing Ltd, so does receive some money and pay UK tax on that. "Looks like" either subbing or an umbrella co.

The cash was building up in the UK Ltd anyway but now the claim is it's doing the same, but is free of tax.

Surely this is going to come unstuck pretty quickly???

And there's still the matter of extracting itz which surely if repatriated is just taxed anyway.

Just sounds like a lot of snake oil...


UpTheIron

4,038 posts

281 months

Wednesday 21st May
quotequote all
Walks like a duck....

TownIdiot

3,453 posts

12 months

Wednesday 21st May
quotequote all
If the company is managed from the UK by a UK tax resident then HMRC would tax it as if it was a UK company.

98elise

29,377 posts

174 months

Wednesday 21st May
quotequote all
UpTheIron said:
Walks like a duck....
This.

LooneyTunes

8,192 posts

171 months

Thursday
quotequote all
macron said:
And there's still the matter of extracting itz which surely if repatriated is just taxed anyway.
Some of the aggressive structures involve making loans from offshore that are never actually going to be repaid.

One of those gave Jimmy Carr a whole new array of jokes.

MaxFromage

2,332 posts

144 months

Thursday
quotequote all
macron said:
-After some sort of webinar,
That's all you need to read to know your acquaintance should unwind this asap.

macron

Original Poster:

11,576 posts

179 months

Thursday
quotequote all
Specifically because of what though?

Anyone can open a company in that manner it seems, Gib basically being entirely happy to host. So that's not illegal.

Any business can charge. And apparently it will hold the brand and a registered set of trade marks so perhaps there is some element of transfer pricing. So that's not illegal.

My reason for making the OP was to find out the why, hence I asked, and perhaps I wasn't clear enough:

macron said:
I wondered if the accounting cognoscenti would like to immediately find flaw with this as it sounds far too good to be true to me:
Just saying "he shouldn't do it" doesn't explain what specifically is wrong with it.

And I'd love to know, as it stinks, but why?

TownIdiot

3,453 posts

12 months

Thursday
quotequote all
macron said:
Just saying "he shouldn't do it" doesn't explain what specifically is wrong with it.

And I'd love to know, as it stinks, but why?
Because if he's a UK tas resident running the company from the UK and operating within the UK he would need to inform HMRC and account for the business as if it was a UK business.

So there's no advantage to be gained.

macron

Original Poster:

11,576 posts

179 months

Thursday
quotequote all
Right, think I have the magic bullet. Might be wrong, it seems.some offshore things are ok, and suspect the "advisors" have some sort of wheeze where they think they're sidestepping this, probably with some sort of pretend role they assign themselves in the apparent business.

https://assets.publishing.service.gov.uk/media/5a7...

mikebradford

2,851 posts

158 months

Wouldn't you just replicate what the major companies do.
Have 2 companies, one offshore eating all the profits, and one on shore earning just enough to take equivalent to the most tax efficient for your everyday needs?

Presumably the issue is the pile of money mounting up offshore becomes taxable if you then try and bring it into the country.

TownIdiot

3,453 posts

12 months

mikebradford said:
Wouldn't you just replicate what the major companies do.
Have 2 companies, one offshore eating all the profits, and one on shore earning just enough to take equivalent to the most tax efficient for your everyday needs?

Presumably the issue is the pile of money mounting up offshore becomes taxable if you then try and bring it into the country.
If you are a UK tax resident it's taxable before you move it into the country

Lefty

17,804 posts

215 months

Presumably easier for said contractor to move and become a digital nomad - if he/she/they can work remotely? Plenty of nice sunny places offering very low tax rates

TownIdiot

3,453 posts

12 months

Lefty said:
Presumably easier for said contractor to move and become a digital nomad - if he/she/they can work remotely? Plenty of nice sunny places offering very low tax rates
Yes if you can break the link with the UK it would work

Lefty

17,804 posts

215 months

180 days?

Does “severing ties” mean selling property?

TownIdiot

3,453 posts

12 months

Lefty said:
180 days?

Does “severing ties” mean selling property?
It's a bit of a sniff test but they do look at stuff like that yes.


mikebradford

2,851 posts

158 months

TownIdiot said:
mikebradford said:
Wouldn't you just replicate what the major companies do.
Have 2 companies, one offshore eating all the profits, and one on shore earning just enough to take equivalent to the most tax efficient for your everyday needs?

Presumably the issue is the pile of money mounting up offshore becomes taxable if you then try and bring it into the country.
If you are a UK tax resident it's taxable before you move it into the country
Could you not in theory let the money pile up offshore, over a number of years.
Live of a small basic income declared in the UK
Then retire abroad.
At the point of moving abroad access the offshore money as your not bringing it into the UK

TownIdiot

3,453 posts

12 months

mikebradford said:
Could you not in theory let the money pile up offshore, over a number of years.
Live of a small basic income declared in the UK
Then retire abroad.
At the point of moving abroad access the offshore money as your not bringing it into the UK
If you are a UK tax resident you'd still be expected to declare the income into the offshore company and be taxed on it.

If you did it for a few years then legged it never to return it's difficult to see what they would be able to do. But it would still be against the rules.

In the vast majority of cases it's very difficult to successfully utilise an offshore company in this way if you are a UK tax payer who lives and works in the UK.

Lefty

17,804 posts

215 months

And we see the Laffer curve in action.

Seeya!

JonPH

53 posts

71 months

You're straight into permanent establishment.

Offshore matters are designed so that middle incoming citizens can't take advantage of them.

macron

Original Poster:

11,576 posts

179 months

JonPH said:
You're straight into permanent establishment.

What does that mean?