UK Structure for international working

Oct 8, 2018
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I'm a British expat in the process of setting up my permananet residency in Ecuador.

I work as a programmer with my wife and we frequently get USA contracts and sometimes UK ones. I need to have an Ecuadorian company as part of my visa residency application.

I'm wondering about the following structure for maximum tax benefits, and avoiding double taxation as Ecuador doesn't have a tax treaty with the USA.

I'm thinking of setting up:
Limited company, "the agency", here in Ecuador, which my wife and I will work for.
Limited company in the UK "the holding company", which will get the contracts from USA and UK, and own the Intellectual Property of my company.

"the holding company" will then commission work to the "the agency", here in Ecuador.

I would pay most of the money to the "the agency"; and retain almost nothing in the UK company, which would retain IP as it's main commodity.

1. Will that avoid double taxation with the USA?
2. Am I right in thinking, that given that I am not an employee of "the holding company" and I am non-resident, that my tax obligations in the UK will be zero, if all of the money goes on business expenses (such as software licenses, server hosting, and paying agencies such as "the agency"?

I'm really stuck on getting this setup, and don't want to spend a fortune on an umbrella company. I discussed this with a professional Ecuadorian accountant; but alas, I don't have much faith in their knowledge.

I thank you ladies/sirs for your responses and will happily provide more information.

Also happy to commission someone to help me set this all up, once I've clarified the scenario, if any of you are looking for a client.


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