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Do I have to corporate tax on foreign income as non-UK resident owner of a private limited company?

Personal Finance & Money Asked by Michael Samuel on March 22, 2021

I’m going to start a UK Limited Company and need to know my tax obligations upfront depending on my specific case:

  1. I’m a Non-UK resident who have never been to the UK and will NOT anytime soon
  2. An agent will create the company for me (formation agent)
  3. They provide their business address to be used as my company’s address for both public records and to receive and forward government and business mail to my home country
  4. I would be the sole owner and director of the company and effectively everything there
  5. This same address is used by thousands of other businesses
  6. I will NOT have any agent to act on my behalf regarding the business
  7. I will NOT have any physical presence in the UK to manage the business
  8. The nature of the business is online games where I sell advertising space in the games to advertisers worldwide INCLUDING UK and this is totally managed through Facebook
  9. Facebook would pay the ad revenue to my PERSONAL US bank account and they would use my business details for "taxing purposes" as they claim
  10. Payments are generated from Facebook’s headquarters in the Republic of Ireland so should NOT be considered UK source income
  11. Payments invoices would NOT include breakdown of the portion of UK advertisers or any just other country so no way to actually know which income is from UK

Regarding the above conditions, since the source of income is NOT originating from UK and I guess I do NOT have a UK permanent establishment in the eyes of the HMRC, I would NOT have to pay corporate tax. Am I right about this or there is something that I’m missing?

Thanks

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