I have husband and wife clients who are the directors and shareholders of a UK limited company which has properties in the UK and which generates an annual net profit from rents of approximately £25 000 which of course is subject to corporation tax.
The situation regarding the directors is as follows.
- The directors normally have a salary of £5 000 p.a. each and draw the rest in dividends.
- They have been resident in Malta for several years and will not return to the UK.
- Their only assets here are the shares in the company.
In order to reduce the charge to corporation tax we are considering including a management charge as a deduction in the profit and loss account for services carried out by the directors.
The directors do genuinely run the company at one remove and are...
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