No. If you do not intend to create a long-term or permanent trading presence in the UK then a contractual arrangement, for example, an agency, distributorship or supplier arrangement may be more suitable.
You should seek professional advice as to whether this would be more tax-efficient than establishing a trading presence in the UK. Subject to the provisions of any relevant double tax treaty, such contracts should be negotiated and signed outside the UK to avoid any suggestion that you are carrying on a trade in the UK and therefore potentially subject to UK tax. However, this is not the sole consideration. The fundamental test is where the operations generating the profits take place. |
