Category: Corporate Services

A Changing Focus Regarding International Tax Planning

International tax planning is becoming increasingly sophisticated, with considerations often far more complex than just seeking the ‘lowest’ rate of corporate tax.

Particularly in markets such as Europe, a location that facilitates cross-border trade and investment is becoming increasingly important for businesses aiming at globalisation and to remain competitive with their peers.

A number of previously popular structures have become difficult to use, especially in markets like the EU, due to non-compliance with OECD, BEPS and Pillar II requirements, which are changing the landscape of international tax planning.

The Madeira International Business Centre (MIBC): An Attractive Option for International Tax Planning

The Madeira International Business Centre (MIBC) has been around since the late 1980s and has seen a series of developments introduced which make it increasingly attractive for international tax planning.

• Madeira IBC companies, that satisfy the minimum substance criteria, benefit from a 5% corporate income tax rate for business conducted internationally in Madeira.

MIBC, based in the Madeira Portuguese Island, has; a specific taxation regime for international services, an industrial free trade zone and a ship registry that is fully integrated into the Portuguese and European legal system. MIBC is also fully compliant with the requirements of the OECD, BEPS and other EU Directives.

Based in the Atlantic Ocean, Madeira is a one-and-a-half-hour flight from the Portuguese capital, Lisbon. The island has taken several active steps to ensure that the important topic of substance is addressed in terms of corporate structuring. Companies in Madeira have predefined substance rules, specifying the criteria needing to be met, to be fully compliant with the regime.

The substance criteria are defined as having at least one employee employed within the first six months of operation and a €75,000 investment in fixed assets, tangible or intangible, within the first two years of operation. Alternatively, there must be six full time employees. All employees need to be based/tax resident in the island of Madeira.

What Advantages Can an MIBC Offer to French Tax Residents?

MIBC companies can be used as holding companies or for trading purposes.

The Double Tax Treaty between Portugal and France, dating originally from 1971, presents a number of tax efficiencies and other benefits, as detailed below:

• Madeira IBC companies, that satisfy the minimum substance criteria, benefit from a 5% corporate income tax rate for business conducted internationally and up to 14.7% for business conducted in the Portuguese national market, with the exclusion of financial service activities.
• Distributions such as dividends, capital gains, interest, royalties and services made to French residents, single or corporate shareholders of the MIBC, will benefit from a FULL exemption from withholding tax in Portugal. This applies to all Portuguese non-residents as long as they are not resident in one of Portugal’s “blacklist” jurisdictions.
• In addition, Portuguese corporates will also be entitled to the participation exemption in Portugal, if holding a participation of at least 10% for 12 consecutive months.
• As a Madeira IBC is a full Portuguese company, it is regarded as an onshore company and is subject to Portuguese legislation. This means that the DTT between Portugal and France is applicable. It only needs to be considered for inbound distributions to French tax residents, as the outbound distributions from Portugal are not subject to tax according to the rules of the Madeira IBC.
• No withholding tax applies when the EU Parent & Subsidiary Directive and/or the EU Interest & Royalty Directive apply.
• The Double Tax Treaty may provide for the following tax on income received in France:
  • Up to 15% tax rate on dividends paid.
  • A 12% tax rate on interest (or 10% in the case of interest on bonds).
  • 5% on royalties.

What Attraction is there for Employees of French Nationality to Move to Madeira?

The non-habitual resident regime attracts a flat personal income tax rate of 20% with no ceiling, making it an attractive reason for employees to relocate.

Why is Madeira Regarded as a Favourable Place to Do Business?

Madeira is regarded as a favourable place to do business in Europe for a variety of reasons:

• Lower operational costs, namely set up fees, costs of employment (less than €15,000 for a full-time employee per annum, including National Insurance), registered office fees, local directors, and other costs associated with the set up and maintenance of a company.
• Simple structure: the structure is easy to administer when compared to other jurisdictions, making the running costs lower and providing fewer operational complexities.
• Madeira IBCs have been approved by the European Commission, due to the definition of Madeira as a less prosperous region and, on this basis, the European Commission has approved a lower tax rate in compensation for Madeira not receiving specific subsidies from the EU.
• This 5% tax rate is guaranteed until the end of 2027 with discussions currently ongoing with the EU for a further extension. The tax rate has been reviewed and renewed every few years since the 1980s.
• The ability to operate and do business in Madeira is straight forward, with a strong pool of talent in Madeira.
  • Typically, Madeirans speak at least two additional languages, in many cases, English and French.
  • With a university situated on the island, students from the IT and other sectors can be employed at a significantly reduced cost, when compared to neighbouring EU jurisdictions.
• Incubation and R&D facilities exist in Madeira, to assist start-up operations.
• European subsidies and grants may be applied, as Madeira forms part of the EU.
• When registering a company through the MIBC, an automatic VAT number is allocated to the company and no separate application needs to be made.

Summary

Madeira should be rightly considered as a ‘new’ essential in relation to corporate structuring, particularly for international business, and as an entry point into the EU market or even a means to doing business in the EU.

Whether it be establishing companies for IT applications, for trading, or other types of services, Madeira is a good fit for virtually all sectors (with the exception of financial services).

Madeira is fully considered to be part of Portugal. Similarly, Madeira companies are also regarded as Portuguese and required to comply with Portuguese laws and regulations.  Madeira is therefore not listed as a blacklist jurisdiction.

Additional Information

If you would like additional information regarding Madeira companies, please contact the Dixcart office in Madeira: advice.portugal@dixcart.com.

It is now May 2023 and the deadline of 31 January 2023, for the registration of overseas entities with property interests in the UK, with Companies House has passed, with no announcement of any further extension. An estimated 13,000 relevant overseas entities had not registered by the deadline, approximately 40% of the total.

All overseas entities that do not register on the Register of Overseas Entities, can face a fine of up to £2,500 per day and potential criminal charges.

Unless the registration process has been dealt with and the information is up to date, it will now no longer be possible for Overseas Entities to buy, charge, sell or lease property (for more than seven years).

If you are involved in any property transaction involving a UK Overseas Entity, you need to take appropriate action now to make sure that any registrations are completed.

What is the Register of Oversea Entities (ROE)?

The ROE is operated by Companies House, and registers information relating to overseas entities who own/ ill own property or are tenants of leases (for a term of over 7 years). The information held on the ROE includes, most importantly, the beneficial owners of the overseas entity or in the absence of such, the managing officers.

In order to register on the ROE, the Overseas Entity (OE) must have their information verified by a UK regulated ‘relevant person’ (as defined in the Money Laundering Regulations), this person can be a solicitor, accountant, or registered agent. Once successfully registered, Companies House provide an Overseas Entity ID Number which will be used by the Land Registry in property dealings.

A closer look at the consequences of failing to register:

An overseas entity that fails to register with Companies House and provide the required information on its beneficial owners will not be registered as the legal owner and will, therefore, be unable to sell or lease the land, or create a charge over it (other than in limited circumstances).

The overseas entity and its officers will also be liable to civil and criminal penalties for failing to register. Such penalties include:

• daily fines
• prison sentences for managing officers.
• limits on the ability to deal with the land (see below).

How will non-compliance be policed at the Land Registry?

The Land Registry is obliged to enter a restriction on the title to any UK land where it is satisfied the registered proprietor is an overseas entity registered on or after 1 January 1999.

The restriction will broadly prohibit the registration of any:

• transfer
• lease for a term of more than seven years from the date of the grant
• charge, unless the overseas entity has fulfilled its registration requirements or is exempt at the date of such disposition.
• An overseas entity purchasing UK land will be unable to be registered as proprietor of that land without demonstrating to the Land Registry that they have complied with the registration requirements (by producing an overseas entity ID).

Summary

It is now more important than ever, if you are involved in any property transaction involving a UK Overseas Entity, that you take appropriate action now, in order to avoid fines and/or potential criminal charges.

If you think you may need to register your overseas entity, please get in touch with the Dixcart office in the UK who will be able to assist you throughout the process: advice.uk@dixcart.com

Overview

Malta has become a popular choice for an increasing number of multinational groups seeking an efficient holding structure. In the article below we examine the Participation Holding Exemption and how it could be of benefit to you, should you consider setting up a Holding Company in Malta.

What is the Maltese Company Participation Holding Exemption?

Participation Holding Exemption is a tax exemption available to Maltese companies that hold more than 5% of the shares or voting rights in a foreign company. Under this exemption, dividends received from the subsidiary company are not subject to taxation in Malta.  

Malta’s participation exemption relieves 100% of the tax on both the dividends derived from a participating holding and on gains derived from the transfer thereof. This exemption is designed to encourage Maltese companies to invest in foreign companies and to promote Malta as an attractive location for holding company structures.

Participating Holding: Definition

 A participating holding is where a company resident in Malta holds equity shares in another entity and the former:

a. Holds directly at least 5% of the equity shares in a company, and this confers an entitlement to at least two of the following rights:

i.    Right to vote;

ii.   Right to profits available on distribution;

iii.  Right to assets available for distribution on a winding up; OR

b.  Is an equity shareholder and is entitled to purchase the balance of the equity shares or has the right of first refusal to purchase such shares or is entitled to sit as, or appoint, a director on the Board; OR

c.  Is an equity shareholder who holds an investment of a minimum €1.164 million (or the equivalent sum in another currency), and such investment is held for an uninterrupted period of at least 183 days; or the company can hold the shares or units for the development of its own business, and the holding is not held as trading stock for the purpose of a trade.

For a holding in a company to be a participating holding, such a holding must be an equity holding. The holding must not be in a company holding, directly or indirectly, immovable property situated in Malta, subject to a few minor exclusions.

Other Criteria

With respect to dividends, the Participation Exemption is applicable if the entity in which the participating holding is held:

1. Is resident or incorporated in a country or territory which forms part of the European Union; OR
2. Is subject to tax at a rate of at least 15%; OR
3. Has 50% or less of its income derived from passive interest or royalties; OR
4. Is not a portfolio investment and has been subject to tax at a rate of at least 5%.

Tax Refunds for Participating Holding Entities

Where the participating holding relates to a non-resident company, an alternative to Malta’s participation exemption is a full 100% refund. The respective dividends and capital gains will be taxed in Malta, subject to double tax relief, however, on  dividend distribution, the shareholders are entitled to a full refund (100%) of the tax paid by the distributing company.

In summary, even when Malta’s participation exemption is not available, Maltese tax may be eliminated through application of the 100% refund.

Domestic Transfers

Malta’s Participation Exemption also applies with respect to gains derived from the transfer of a participating holding in a company resident in Malta. Dividends from companies ‘resident’ in Malta, whether participating holdings or otherwise, are not subject to any further taxation in Malta in view of the full imputation system. For further information please speak to Dixcart: advice.malta@dixcart.com

Sale of Shares in a Malta Company by Non-Residents

Any gains or profits derived by non-residents on a disposal of shares or securities in a company resident in Malta are exempt from tax in Malta, provided:

• The company does not have, directly or indirectly, any rights with regards to immovable property situated in Malta, and
• the beneficial owner of the gain or profit is not resident in Malta, and
• The company is not owned and controlled, directly or indirectly by, nor acts on behalf of an individual/s ordinarily resident and domiciled in Malta.

Additional Benefits Enjoyed by Maltese Companies

Malta does not levy withholding taxes on outbound dividends, interest, royalties and liquidation proceeds.

Maltese holding companies also benefit from the application of all EU directives as well as Malta’s extensive network of double taxation agreements.

Dixcart in Malta

The Dixcart office in Malta has a wealth of experience across financial services, and also offers legal and regulatory compliance insight. Our team of qualified Accountants and Lawyers are available to set up structures  and to manage them efficiently .

Additional Information

For further information about Maltese companies matters please contact Jonathan Vassallo, at the Dixcart office in Malta: advice.malta@dixcart.com.

Alternatively, please speak to your usual Dixcart contact.

Do you have a business in Cyprus and are you looking for accounting services?

Cyprus companies: Accounting, Annual General Meeting and Annual Return Requirements

• Under the Cyprus Companies Law, the directors of every company are responsible for the bookkeeping necessary for the preparation of the financial statements of the company that need to be filed with the Registrar of Companies. The financial statements are accompanied by the Management Report. Newly formed companies do not have to submit financial documents for the first year of activity, but the documents must be registered at the Registrar of Companies within 18 months of the date of incorporation.

• Under the Cyprus Companies Law, all companies must have their financial statements audited and signed by a Cyprus registered auditor.

• Companies with subsidiaries need to present consolidated financial statements.

• Cyprus companies must hold an Annual General Meeting (AGM) every year and no more than 15 months should lapse between the first AGM and the subsequent one.

Tax Obligations of Cyprus Companies

Cyprus Companies, for tax purposes, are identified as tax resident or non-tax resident. A company, irrespective of where it is registered, is taxed only if it is a tax resident of Cyprus.

A Cyprus company is tax resident in Cyprus if the management and control is in Cyprus, regardless as to whether the company is also registered in Cyprus. Generally, tax resident companies are taxed at 12.5% of their business profit.

• All companies have a default year-end of 31^st December, but may elect another date. Companies must file an income tax return and financial statements within 12 months of their year-end.

How Can Dixcart Help?

Dixcart can assist with the accounting process and help ensure that the process is as simple and timely as possible.

We are also experienced in liaising with the chosen auditor and can suggest a number of competent auditors, if required.

Please speak to Katrien de Poorter, at our office in Cyprus: advice.cyprus@dixcart.com

A Changing Focus Regarding International Tax Planning

International tax planning is becoming increasingly sophisticated, with considerations often far more complex than just seeking the ‘lowest’ rate of corporate tax.

Particularly in markets such as Europe, a location that facilitates cross-border trade and investment is becoming increasingly important for businesses aiming at globalisation and to remain competitive with their peers.

A number of previously popular structures have become difficult to use, especially in markets like the EU, due to non-compliance with OECD, BEPS and Pillar II requirements, which are changing the landscape of international tax planning.

The Madeira International Business Centre (MIBC): An Attractive Option for International Tax Planning

The Madeira International Business Centre (MIBC) has been around since the late 1980s and has seen a series of developments introduced which make it increasingly attractive for international tax planning.

• Madeira IBC companies, that satisfy the minimum substance criteria, benefit from a 5% corporate income tax rate for business conducted internationally.

MIBC, based in the Madeira Portuguese Island, has; a specific taxation regime for international services, an industrial free trade zone and a ship registry that is fully integrated into the Portuguese and European legal system, and is fully compliant with the requirements of the OECD, BEPS and other EU Directives.

Based in the Atlantic Ocean, Madeira is a one-and-a-half-hour flight from the Portuguese capital, Lisbon. The island has taken several active steps to ensure that the important topic of substance is addressed in terms of corporate structuring. Companies in Madeira have predefined substance rules, specifying the criteria needing to be met, to be fully compliant with the regime.

The substance criteria are defined as having at least one employee employed within the first six months of operation and a €75,000 investment in fixed assets, tangible or intangible, within the first two years of operation. Alternatively, there must be six full time employees. All employees need to be based/tax resident in the island of Madeira.

What Advantages Can an MIBC Offer to Turkish Tax Residents?

MIBC companies can be used as holding companies, however due to Controlled Foreign Company (CFC) implications in Turkey, this may not be the most tax efficient structure for a Turkish tax resident earning passive income.

Trading or operational companies in the MIBC therefore offer the greatest potential benefits.

The Double Tax Treaty between Turkey and Portugal presents a number of tax efficiencies, as detailed below:

• Madeira IBC companies, that satisfy the minimum substance criteria, benefit from a 5% corporate income tax rate for business conducted internationally and up to 14.7% for business conducted in the Portuguese national market, with the exclusion of financial service activities.
• Distributions such as dividends, capital gains, interest, royalties and services made to Turkish residents, single or corporate shareholders of the MIBC, will benefit from a FULL exemption from withholding tax in Portugal. This applies to all Portuguese non-residents if they are not resident in one of Portugal’s “blacklist” jurisdictions.
• In addition, Portuguese corporates will also be exempt, if holding a participation of at least 10% for 12 consecutive months.
• As a Madeira IBC is a full Portuguese company, it is regarded as an onshore company and is subject to Portuguese legislation. This means that the DTT between Portugal and Turkey is applicable. It only needs to be considered for inbound distributions to Turkish tax residents, as the outbound distributions from Portugal are not subject to tax according to the rules of the Madeira IBC.
• The DTT agreement provides for a 5% tax rate where dividends are paid to a company, other than a partnership, that directly holds at least 25% of the capital of the company paying the dividends, for a minimum two-year period before the dividends are paid; otherwise, the rate is 15%.
• A 10% tax rate applies to interest on loans, where the duration of the loan is a minimum of two years; otherwise, the rate is 15%.

How Easy Is It for Turkish Nationals to Move to Madeira?

The Digital Nomad Regime in Madeira makes it attractive for a non-EU employee from Turkey, or elsewhere, to relocate and benefit from the personal tax regime available. The non-habitual resident regime attracts a flat personal income tax rate of 20% with no ceiling.

Why is Madeira Regarded as a Favourable Place to Do Business?

Madeira is regarded as a favourable place to do business when compared to other European jurisdictions for a variety of reasons:

• Lower operational costs, namely set up fees, costs of employment (less than €15,000 for a full-time employee per annum, including National Insurance), registered office fees, local directors, and other costs associated with the set up and maintenance of a company.
• Simple structure: the structure is easy to administer when compared to other jurisdictions, making the running costs lower and providing fewer operational complexities.
• Madeira IBCs have been approved by the European Commission, due to the definition of Madeira as a less prosperous region and, on this basis, the European Commission has approved a lower tax rate in compensation for Madeira not receiving subsidies from the EU.
• This 5% tax rate is guaranteed until the end of 2027 with discussions currently ongoing with the EU for a further extension. The tax rate has been reviewed every few years since the 1980s.
• The ability to operate and do business in Madeira is straight forward, with a strong pool of talent in Madeira.
  • Typically, Madeira people speak at least two languages, in almost all cases, including English.
  • With a university situated on the island, students from the IT and other sectors can be employed at a significantly reduced cost, when compared to neighbouring EU jurisdictions.
• Incubation and R&D facilities exist in Madeira to assist start-up operations.
• European subsidies and grants may be applied, as Madeira forms part of the EU.
• When registering a company through the MIBC, an automatic VAT number is allocated to the company and no separate application needs to be made.

Summary

Madeira should be rightly considered as a ‘new’ essential in relation to corporate structuring, particularly for international business, and as an entry point into the EU market.

Whether it be establishing companies for IT applications, for trading, or other types of services, Madeira is a good fit for virtually all sectors (with the exception of financial services).

Madeira is fully considered to be part of Portugal. Similarly, Madeira companies are also regarded as Portuguese and required to comply with Portuguese laws and regulations. Madeira is therefore not listed as a blacklist jurisdiction.

Additional Information

If you would like additional information regarding Madeira companies, please contact the Dixcart office in Madeira: advice.portugal@dixcart.com.

Malta Enterprise currently offers a variety of diverse funding options, aimed at developing and enhancing small to medium sized businesses on the island. In this article we focus on the Soft Loan. It is designed to support existing businesses to; accelerate plans to establish new products, enter a new geographic market, address environmental concerns, and/or digitise processes.

Companies that meet the requirements can benefit from a Soft Loan covering part of the funding requirements, up to €1,000,000.

How Does it Work?

An eligible undertaking may be supported through a soft loan to:

a) facilitate a development or expansion project based on a business plan to develop a new product or enter a new geographic market

b) address environmental issues such as; water usage, water treatment, waste treatment, reduction, and reuse

c) optimise business processes through digitalisation and advanced technologies

d) projects aimed to achieve a high level of sustainability

Supported projects must have an implementation period which is not longer than eighteen months and the loan may cover up to 75% of the costs related to the proposed project, including the; procurement of assets, wage costs, know-how and other non-recurring costs.

Details About the Loan

It is important to note that the loan is by way of collateral, secured by a special ‘hypothec’ covering at least fifty percent (50%) of the loan amount. The loan amount cannot exceed:

a) €1,000,000maximum fundingthat must be repaid over a five year term. For organisations involved in road freight transport, the maximum funding is €500,000.

b) Alternatively, if the loan is to be re-paid over ten years, the maximum funding is €500,000, or €250,000 for organisations involved in road freight transport.

Interest Rate

Malta Enterprise charges a very competitive rate of interest that is not lower than 0.5%, established after considering the project and the prevailing European Central Bank reference rate.

The amount not covered by the loan issued by Malta Enterprise, must be financed through a loan issued through a commercial bank and/or through the reserves of the organisation, or other funds considered to be the organisation’s own funds, which must be specifically allocated to the project and deposited with a Commercial Bank.

The loan is repayable within a period of five years, or ten years as outlined above, and Malta Enterprise may agree a moratorium of a maximum twenty-four months for the loan to the relevant organisation, as long as the repayment remains scheduled to be completed within the five or ten year period, as applicable.

Additional Assistance in Malta

This support measure can be combined with the other assistance, such as: The Research and Development Grant: https://www.dixcart.com/setting-up-a-company-in-the-eu-malta-funding-solutions/

How Can We Help You?

Dixcart Malta have a wealth of experience across financial services, offering legal and regulatory compliance insight and helping to implement transformational technology and organisational change. 

Our team of professionals can assist you with the application process and make recommendations with regards to the funding being proposed, as well as preparing the relevant paperwork to ensure a smooth and seamless process, to obtain the relevant finance required.

We will guide you each step of the way and detail the specific criteria required, depending on the activity of the company.

Additional Information

For further information about Malta and the assistance available to companies, please contact Jonathan Vassallo, at the Dixcart office in Malta: advice.malta@dixcart.com. Alternatively, please speak to your usual Dixcart contact.

Action Still Needed

The Deadline Has Passed – Action Still Needed

The deadline of 31 January 2023, for the registration of overseas entities with property interests in the UK, with Companies House has now past.

An estimated 13,000 relevant overseas entities had not registered by the deadline, approximately 40% of the total. 

Considerable work needs to be committed to the verification process, before an application for registration can be made.  

In addition, overseas entities that owned a qualifying estate on February 28, 2022 and have subsequently disposed of their interest, are also caught by the rules.

A summary is listed below. For comprehensive detail, please see our previous article here.

Who needs to register?

The beneficial owner of any overseas entity (being a corporate body, partnership or other legal person) governed by the laws of a country or territory outside of the United Kingdom that owns, leases or disposes of qualifying real estate.

Submission of information and verification

The register is a digital service with information submitted in English.

Before any application for first registration or later updating applications/rectifications and amendments can take place, the information will be subject to formal verification by a relevant person.

Broadly, a relevant person includes an independent legal professional, financial institutions, auditors, estate agents, auction platforms etc. 

Once the information has been verified the relevant person will need to confirm to the  Companies House Registrar that it has completed verification in accordance with the new Act and regulations and provide a  statement complying with Part 2 (5) of The Register of Overseas Entities (VPI) Regulations 2022.  If the relevant entity has made no relevant dispositions between 28 February 2022 and the date the application is made, the application must state this.

The information itself must be retained by the relevant person for a period of 5 years.

What happens once registration is accepted?

Companies House then publish the identity on a public register and assign a unique Overseas Entity ID. The name of the relevant entity and their agent will be available to the public on the Companies House website. The Overseas Entity ID will be required by the Land Registry before it registers any dealings relating to real estate in England & Wales.

The 2022 Act requires registered entities to update their information annually.

Secondary legislation allows individuals to be able to protect some of their information from public disclosure in limited circumstances (if it can be shown that an individual, or the people they reside, with will be at serious risk of violence or intimidation).

Failure to comply with registration and/or within the time limits imposed?

In England and Wales a person guilty of an offence is liable on summary conviction to a daily fine of up to £2,500 or unlimited fines and a prison sentence of up to 5 years. Failure to register will also prevent any dealings with the real estate in question.

What can Dixcart do to help you?

We can keep you up to date of the latest developments, assist and advise you on your obligations and aid in collecting the required information.

We can also verify the required information for you and make the application for registration to Companies House and communicate the unique Overseas Entity ID number to you as well as process annual returns.

Additional Measures in the Future

Following the introduction of the  Economic Crime (Transparency and Enforcement) 2022 Act (“ECTE ACT”), which came into force on 01 August 2022, the UK Government is now seeking further measures with the introduction of the Economic Crime and Corporate Transparency Bill, which is already past Committee stage in the House of Commons. 

The register of overseas entities will be amended to maintain consistency with changes intended to the Companies Act 2006.

Amongst the other far reaching and significant changes intended by the Bill are:

• reforms to Companies House including the introduction of identity verification for all new and existing registered company directors
• reforms to prevent the abuse of limited partnerships by tightening registration requirements and increasing transparency
• additional powers to seize and recover suspected criminal crypto assets by boosting criminal confiscation powers
• reforms to give businesses more confidence to share information in order to tackle money laundering and other economic crime
• new intelligence gathering powers for law enforcement and removal of nugatory burdens on business.

Additional Information

If you have any questions or think you may need to register your overseas entity, please get in touch with the Dixcart office in the UK: advice.uk@dixcart.com.