Client case study
Determination of corporate residency
Background: We were approached by an offshore company trading in the Far East looking to expand its operation to the UK by formation of a UK company. Some board members would be relocating to the UK while some would regularly travel to the UK for business.
How we helped: The initial enquiry to us was in connection with basic compliance work for the UK entity, but after analysing the structure it quickly became apparent that the relocation of the board of directors would bring the offshore profits into UK corporation tax, even though the trade remained abroad. By recommending a change to the decision hierarchy, the non-UK profits were retained abroad, leaving only the UK profits taxable as originally intended.