Corp Tax - UK/Ireland legislation & transfer pricing!

Loco

Hi,

I own a UK company which provides IT consultancy services to financial companies both on site in London and remotely from Cork. The services could be fully offered from Cork. They benefit global teams/departments, usually New York/London/Singapore.

The service contracts are generally between my UK company and the UK registered clients.

Is there anyway I could legally pay Irish corp tax through an Irish company for these services rather than in the UK.

Would it simply be a case of amending the contract to be between my Irish company and the UK companies and disregarding the UK company?

Or would there be some obscure transfer pricing type way of doing this?

Any information or links you may have on the legislation around this would be appreciated!

Thanks

Toblerone1978

Loco wrote: »

Hi,

I own a UK company which provides IT consultancy services to financial companies both on site in London and remotely from Cork. The services could be fully offered from Cork. They benefit global teams/departments, usually New York/London/Singapore.

The service contracts are generally between my UK company and the UK registered clients.

Is there anyway I could legally pay Irish corp tax through an Irish company for these services rather than in the UK.

Would it simply be a case of amending the contract to be between my Irish company and the UK companies and disregarding the UK company?

Or would there be some obscure transfer pricing type way of doing this?

Any information or links you may have on the legislation around this would be appreciated!

Thanks

It depends if the Irish company has a UK permanent establishment, rather than transfer pricing.

It sounds to me that based on the above, you probably don't have a permanent establishment in the UK, but one in Ireland; but until you talk to an accountant about this, it would be wrong to act on my assumption.

For more info, view the double taxation agreement between the UK and Ireland (on the Revenue website) to what a permanent establishment is.

Mr. Incognito

Read the charter

Seek professional advice

Thread closed