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Global Tax Insight Tax risks and opportunities when sending employees and directors to the Global Tax Insight Tax risks and opportunities when sending employees and directors to the UK 28 January 2016

Agenda • Blick Rothenberg LLP – who we are • Employee and directors • Agenda • Blick Rothenberg LLP – who we are • Employee and directors • • UK tax? UK payroll / social security? Opportunities recent changes Companies • • • UK tax? “Branch” Subsidiary

Employee and directors Employee and directors

When is UK employee tax due? § No UK-Brazil income tax treaty! § UK When is UK employee tax due? § No UK-Brazil income tax treaty! § UK tax from day 1 (no 183 day exemption) § UK statutory residence test § § § Non UK tax resident – UK source UK resident – worldwide income versus “remittance basis” Unilateral credits to avoid double tax

Key opportunities to save UK tax § Temporary living expenses <24 months § Deductions Key opportunities to save UK tax § Temporary living expenses <24 months § Deductions for work outside the UK < 36 months § Shelter offshore income – remittance basis

UK employer obligations § “UK presence” or “UK host” organisation? § UK tax – UK employer obligations § “UK presence” or “UK host” organisation? § UK tax – operate UK payroll withholding from day 1 § Employee versus self employed § STBV – treaty residents only

UK employer obligations § Some common payroll misconceptions X Brazilian withholding X Brazilian employee UK employer obligations § Some common payroll misconceptions X Brazilian withholding X Brazilian employee X Salary paid Brazil ü If a UK “host employer” - operate a UK payroll § Cash flow management § Non resident directors: § Tax returns § Expense reporting

Social security tax (employer and employee) § Different rules! § 52 week - exemption Social security tax (employer and employee) § Different rules! § 52 week - exemption from UK social security tax provided § Remain employed outside the UK § Ordinarily live outside the UK § Pay from week 52 – no notification from HMRC § Other nationalities/residents – Certificate of coverage / A 1

Latest updates § HMRC guidance on expenses § Changes to expense reporting / “dispensations” Latest updates § HMRC guidance on expenses § Changes to expense reporting / “dispensations” (6 April 2016) § Pension contributions -> £ 10, 000 (6 April 2016) § Deemed domicile > 15 years (6 April 2017)

Companies Companies

UK Business – when is tax due? “PLACE OF BUSINESS” – Business Establishment not UK Business – when is tax due? “PLACE OF BUSINESS” – Business Establishment not taxable • Ancillary or incidental to business as a whole • Checking out the market • Administration office • Registration at Companies House • Payroll obligation • Generally not subject to corporate tax

UK Business continued … “BRANCH” – Business Establishment taxable • Trading presence • Move UK Business continued … “BRANCH” – Business Establishment taxable • Trading presence • Move from ‘representative office’ to branch • Registration at Companies House • Tax considerations • File accounts of overseas company • No audit

UK Business continued … SUBSIDIARY COMPANY • Limited liability • Incorporation at Companies House UK Business continued … SUBSIDIARY COMPANY • Limited liability • Incorporation at Companies House • UK audit, if two of the following breached on a group basis: (a) revenues > £ 6. 5 m; (b) total gross assets > £ 3. 26 m; (c) employees > 50

Contact us Mark Abbs Tel: +44 (0)20 7544 8744 Email: mark. abbs@blickrothenberg. com Contact us Mark Abbs Tel: +44 (0)20 7544 8744 Email: mark. [email protected] com