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A.Valcke, Solicitor
Category: International Tax
Satisfied Customers: 0
Experience:  Solicitor with 14+ years of international legal experience.
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I have a business that sells advertising space on a website.

Customer Question

I have a business that sells advertising space on a website. A customer will register an account, input the details of their advert and make payment for the advert. The advert will then go live on the website for a set number of days.

In the following hypothetical company structure (for tax and legal purposes), where is the contract of sale executed:

HONG KONG Offshore Company (owns IP including domain name, website code) - No staff in hong kong

CYPRUS Company (operates the website for Hong Kong co, accepts payments for sales made on the website) - staff in numbers

UK Company (customer service, dealing with customer enquiries) - staff in numbers, works on a contract basis for either hong kong co or cyprus co

As all of the sales take place online

is it the place that the IP is held (the company that own the website business) ie Hong Kong

or the place the website business is managed from and developed ie Cyprus that the contract of sale takes place for the sale of the advertising to the end user
Submitted: 4 years ago.
Category: International Tax