Hello, I am Keith, one of the experts on Just Answer, and pleased to be able to help you with your question.
I am of the opinion that you will be taxed on these dividends as follows. The first 5K is tax free and the balance will be taxed:
100K - 5K - 11K [Personal Allowance] leaves 84K exposed to taxation. The first 32K at 7.5% [2.4K] and the balance at 37.5% [19.5K]; total tax due 21.9K ie a tad under 22K.
Any tax deducted by the HK authorities would, under the Double Taxation Treaty between the UK and HK, be allowed as a tax credit against the UK liability on the same income stream.
I do hope that you have found my reply of assistance.
I cannot see how the activities of a company domiciled and operating from HK could be assessed for UK Corporation Tax (CT). That is a matter for the HK authorities. CT is only levied on companies not individual shareholders and directors. As an individual you will be paying UK Income Tax (IT) as I explained.
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Thank you for your support.
Good old Pinsent Mason. When I was at school one of my school friend's father was a partner in what was then Pinsents!
The key to this is not day to day control, but central control viz:
'Central management and control is not the same as the day-to-day management of the business. Ordinarily, the place where a company is centrally managed and controlled will be the location where the final decisions that bind the company are made. It will be the place where matters of general policy and strategy for the company are made.'
Naturally you will ensure that such decisions are taken outside the UK so the central management and control will not be UK located and thus the liability to UK taxation would not apply.