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Posted Mon, 12 Aug 2024 08:37:04 GMT by Bertiefresh Fresh
I am looking for some guidance. I have emailed HMRC over two weeks ago and have had no response. My company incorporated in England and Wales is currently based in the UK with a small warehouse, which hold some stock, we have no staff. At the moment we have one director in the UK and one living in the UAE. Potentially the UK Director will be moving on in a few months. This will leave one director running the company from the UAE. Reading all the documentation this would leave the company to be a NRTP. My question would be due to treaty rules regarding tax, would the company be liable for corporation tax in the UK or the UAE ? Please no links to Articles by HRMC , they will produce more questions than answers !! Thanks in advance
Posted Wed, 14 Aug 2024 10:25:01 GMT by HMRC Admin 25 Response
Hi Bertiefresh Fresh.
You will need to write in with full details.
You may also wish to consult our guidance on the Migration of a company which is published on gov.uk.
Alternatively you should seek professional assistance from a Tax Agent.
Outward Migration guidance is found in the below link:
CTM34195 - Residence: outward company migration: guidance notes for migrating companies 
Thank you. 
Posted Wed, 14 Aug 2024 11:12:49 GMT by Bertiefresh Fresh
Thank you for your response. I have read the document you linked to. The company will still have a physical presence in the UK via a small warehouse. It will just be the Director who will be abroad as such I am sure the company would be required to submit tax returns to HMRC along with the companies house obligations ?
Posted Fri, 16 Aug 2024 15:14:38 GMT by HMRC Admin 25 Response
Hi 
Sorry, but we do not have enough information to make an informed response to your query.
You can contact us here:
Corporation Tax: general enquiries
Or you should seek professional advise from a Tax Advisor or similar  professional.  
Thank you. 

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