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Posted Wed, 22 Nov 2023 00:21:04 GMT by LF
I'm planing to leave the UK to become resident in a EU country, but I want to keep my UK limited company open as I'm expecting to continue contracting through it (mostly remotely). If I'm resident outside of the UK, but my company is registered in the UK, where do I pay my company taxes? And how do I keep paying myself salaries and dividends? And how and where are these taxed?
Posted Thu, 23 Nov 2023 08:57:24 GMT by HMRC Admin 20 Response
Hi LF,
Based on the limited information provided you will need to ensure the company doesn’t become resident under the domestic law of your new country of residence.  
If it does, you will need to consider the Double Taxation Treaty in place between the UK and that country to determine where the company is resident for treaty purposes.  
The treaties can be accessed on our website at Tax treaties.  
Assuming the company doesn’t become resident under the domestic law of your new country of residence, the company will remain solely resident in the UK by virtue of its incorporation in the UK.  
This is on the basis that taxing rights of the company's worldwide profits are retained in the UK unless the company trades through a branch elsewhere.  
The company can continue to pay you dividends and a salary, but the taxation of these will depend on where you personally are tax resident.  
Again you would need to consult the relevant Double Taxation Treaty with the UK to determine this.  
Aside from this I cannot comment on matters relating to personal tax, you will need to contact Self Assessment and PAYE directly.
Thank you.
Posted Thu, 23 Nov 2023 11:52:53 GMT by LF
Thank you for this. Regarding this point "you will need to ensure the company doesn’t become resident under the domestic law of your new country of residence", how do I ensure this? The EU country is Portugal.
Posted Tue, 28 Nov 2023 14:32:19 GMT by HMRC Admin 17 Response


Hi ,
 
Company residence can be complex and it depends on several considerations.

This includes ensuring control and management of the company remains in the UK and having regard for the company’s physical presence in the EU country.

It is important to understand the tax residency rules of both the UK and EU country, and to utilise tax treaties and comply with laws to prevent unintended tax residency. 

I would advise you to seek guidance from a  tax professional who specializes in international tax matters and can provide tailored advice based on your company's specific circumstances.

Guidance can also be found at: INTM120020 - Company residence: what this guidance replaces - HMRC internal manual - GOV.UK (www.gov.uk)   . 

Thank you  .

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