Readers' forum : Outsider trading

I have a client who lives in several countries but is domiciled in Ghana. He will never be in the UK for more than 183 days in any tax year but sometimes does not fall far short of that figure. He has formed a company registered in the UK to operate a timber import/export business. His company will be sourcing timber in countries outside the EU such as South Africa and selling the same timber to other countries outside the EU such as China. The timber will never come through the UK.

His company will invoice China for the timber sold and will receive an invoice from South Africa. All transactions will go through the UK books. Some of his deals may be on a commission basis under which one country outside the EU invoices another country outside the bloc and my client’s company will issue...