Considerable care has to be exercised using offshore companies, and their use is not a universal panacea. A UK based investor who buys and owns an offshore company will find, certainly if they become subject to an in depth HMRC investigation that irrespective of where a company is registered, it will (following a string of legal precedence going back 100 years) be regarded as UK resident and so subject to UK Corporation tax on both rental income and capital gains if control is exercised in the UK by either shareholders or directors, including shadow directors.

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