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Is the UK LLP King for ex-UK resident?

Eurocash

New member
Sep 25, 2022
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Europe
Activity: buying/selling domain names
Nationality: British
Current location: Ireland
Potentially planning to move to Malta or Cyprus.
Annual profit: 300,000 to 400,000 Euros, possibly more if a couple of larger deals come to fruition.

I am looking at options for company incorporation at present.

So far I have been fixated on the Malta/Cyprus fiscal unit set-up to achieve 5% corporation tax whilst keeping the company in the EU and benefitting from easier banking access etc.

Corporate substance in Malta for the trading activity is not much of an issue since I already travel there for genuine business activity: meetings, conferences etc. and I have clients there.

However, looking at the fees for incorporation + ongoing management of the set-up I would need for the two companies + audited financial statements for both MT + CY companies + the fiscal unit, it's looking like quite an expensive exercise (15 - 20k euros per annum - no plans to "cut corners")

I could simply incorporate in Ireland and avail of a 12.5% corporation tax rate here without any issues at all, and very low recurring annual costs.

Just a little note on the personal situation: I have non-dom status here, so as long as I'm living off my savings and not remitting into Ireland, I don't have a personal tax liability here.

However, the savings I brought to Ireland are unfortunately not unlimited therefore I can't stay here forever if I want to avoid the high personal tax rates, and so I will likely be moving on within a year or so.

Back to company matters:

Is there a simpler set-up than the Malta/Cyprus fiscal unit which would see me achieve similar or better rate of corporation tax without the high costs and complexity?

To be honest, more than the cost, it's the 3 sets of audited financial statements that is bothering me 1 for each company + the set for the fiscal unit. It just seems like overkill for my level of business.

Are there options in Asia, like Hong Kong/Singapore? Or am I just storing up potential problems for myself since I wouldn't be able to show trading there, and realistically, I'm not going to spend any time there.

Taking all of this into account, is a UK LLP out of the question? I'm a British national, so there's no problems setting it up and getting banking. I will travel to the UK to see family etc. so it's easy to show that the company is not a "sham", and I have UK clients/vendors too.

We all know that the UK LLP itself does not generate a tax bill, the partners are taxed >>> if partner has residency in a 0% or low tax jurisdiction >>> simple and optimal set-up?

Please critique this as harshly as you like - bonus points if you can be constructive!
 
What is the advantage of a UK LLP over a US LLC in your case?

And why not just use a Singapore or Hong Kong offshore company if there is no PE risk in Ireland? It will cost you 3k per year with no taxes.
 
What is the advantage of a UK LLP over a US LLC in your case?
I'm British, so I'm much more comfortable and familiar dealing with accountants to have annual accounts prepared for the LLP as opposed to doing that in the United States.

I'm sure there's no issues with getting NEO bank/EMI's for a US LLC, but I can easily get local bank accounts opened in the UK + EMI if I want it.

I'll never/very seldom travel to the US, but I'll be back in the UK at least a few times per year to see family etc.

Not discounting the US LLC by any means, but those are my answers to your question.

The other slight problem I'm trying to research is how Cyprus would view any profits from the UK LLP remitted there. It's 0% on dividends, but shares of a partnership's profits are not the same as dividends, so could be opening up an issue.

The simplest structure appears to be to set-up an Irish Ltd since I'm here, stomach the 12.5% corporation tax but do everything I can to legitimately reduce that via accountants and then remit the dividends to Cyprus where I would pay 0% tax if resident there.
 
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