UK Tax - Don´t Get Caught!

Companies that are not incorporated in the UK can become liable for UK tax (i) by virtue of their central management and control being exercised in the UK which results in them being UK tax resident, (ii) if they carry on a trade in the UK through a permanent establishment, or (iii) if they have UK source income (e.g. rental income).

If an Offshore Company is resident within the UK for UK tax purposes, it will be taxable on its worldwide income and gains, wherever arising, and whether the income or gains are received in the UK or held overseas.

Where an Offshore Company carries on a trade in the UK through a permanent establishment, those associated profits will be chargeable to UK corporation tax as will chargeable gains realised on property used or held for the purposes of the trade carried on by the permanent establishment.