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Posted Tue, 23 Jan 2024 10:45:19 GMT by
I am UK tax resident in year of assessment 2022/2023. I am also a sole director and shareholder of a overseas limited company which hold properties overseas, not in UK. The foreign limited company already appoint an representative to handle the activities with tenants. E.g. Sign tenancy agreement, deal with property agent, etc. Under the rule from HMRC, It had not any permanent establishment in UK. So no need to report to HMRC, right?
Posted Wed, 31 Jan 2024 14:13:39 GMT by HMRC Admin 13

The general rule is that a company which is not resident in the UK has to pay UK Corporation Tax only if:

• it has a permanent establishment in the UK
• the economic activity that generates its profits is carried out in the UK

Further guidance on company residence can be found at
INTM120210 - Company residence: guidance originally published in the International Tax Handbook - HMRC internal manual

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