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Posted Tue, 04 Jun 2024 18:03:28 GMT by Mike Thomson
If I were to set up a UK LTD company and move to the Netherlands in the future and become a tax resident, would I be liable to pay corporation tax there, due to Permanent Establishment? I would be the sole employee, and all business activities would be done online in my personal residence. I am confused as there would be no "physical business site", but it would be managed completely in the Netherlands.
Posted Fri, 07 Jun 2024 09:17:21 GMT by HMRC Admin 25 Response
Hi Mike,
As Corporation Tax is self-assessed, HMRC is not able to provide a ruling on residency on this forum.
You will need to consult the relevant Double Taxation Treaty between the UK and the Netherlands to establish the nature of its tax liabilities depending on the company's circumstances.
These treaties contain articles relating to the right to taxation of different types of income between countries and how to establish an individual's or a company's residence.
They will usually also contain an article based on what consitutes a permanent establishment.
It is up to the company to ascertain its liability to tax and its residence based on the information in these articles.
The link to the Double Taxation Treaties currently in force are listed here:
Tax treaties
Thank you. 
 

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