Where will I pay tax? UK company with Australian residence
Hello tax folks! My husband and I recently established a business that's officially registered in Scotland, but we're actually living and working from New Zealand. We set up a UK-based payment system that converts NZ dollars to British pounds and deposits them into an overseas account. When we registered the company, we listed a Scottish address for the business but put our actual New Zealand addresses for our personal info. I'm really confused about where our tax obligations lie - do we pay taxes to the New Zealand tax department or to HMRC in the UK? Since all our revenue is already in pounds, would it make financial sense to just pay UK taxes rather than converting everything back to NZ dollars to pay taxes in New Zealand? Seems like we'd lose a lot in conversion fees. Could someone please walk me through how this typically works? I'm completely lost about international tax requirements. Thanks in advance! :
18 comments


Hannah Flores
This is actually a complex situation that could involve tax obligations in both countries. You likely have what's called "permanent establishment" in New Zealand since you're physically operating from there, regardless of where your company is registered. Most countries tax based on where the economic activity actually occurs. In your case, you'll probably need to pay corporate taxes in the UK since the company is UK-registered, but you may also have personal income tax obligations in New Zealand as residents. This is because most countries have residency-based taxation for individuals. Converting currency for tax purposes doesn't typically save money - tax authorities care about where the value is being created, not which currency you use.
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Kayla Jacobson
•But what if they're only temporarily in New Zealand? Like if they're planning to move back to the UK in a year or so? Would that change anything?
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Hannah Flores
•If it's truly temporary, that could potentially change things. Tax residency in New Zealand typically applies if you're present for more than 183 days in a 12-month period, or if you have a "permanent place of abode" there. For a UK company with temporary directors abroad, you might still have what's called "central management and control" in the UK if strategic decisions are made there, which could affect where the company itself is considered tax resident. However, this gets complicated quickly and the rules can vary based on the specific treaty between countries.
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William Rivera
After dealing with similar international tax headaches, I found this amazing AI tool that helped sort through all the conflicting advice. Check out https://taxr.ai - it's specifically designed to analyze international tax situations like yours. I uploaded my company docs and residency info, and it gave me a clear breakdown of my tax obligations in multiple countries.
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Grace Lee
•Does it actually work for overseas businesses though? I tried a different tax helper thing last year and it completely messed up my US-Canada situation because it didn't understand the tax treaty.
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Mia Roberts
•How does it handle currency conversion issues for tax calculations? That's always been my biggest headache with my Singapore/Australia situation.
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William Rivera
•It absolutely works for overseas businesses - it's actually specialized for international situations and understands tax treaties between major countries. It's completely different from those basic tax calculators. For currency conversions, it handles all that automatically using daily or average exchange rates depending on your situation. You can even select which method you want to use for calculations. It saved me hours of spreadsheet work trying to convert euro to dollars for my quarterly filings.
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Mia Roberts
Just wanted to update after trying taxr.ai from the recommendation above. It was actually super helpful for my situation! I've been struggling with my Australia/Singapore tax situation for ages, and the tool immediately identified that I had "permanent establishment" in both places but showed me how to properly allocate income to minimize double taxation. The currency conversion feature alone was worth it - automatically applied the right exchange rates for different reporting periods. Definitely check it out if you're dealing with international tax complications.
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The Boss
I went through this exact nightmare last year with my UK/Germany setup. After months of trying to get through to HMRC for clarification, I found https://claimyr.com which got me connected to a real HMRC agent within about 20 minutes when I'd been trying for weeks. They have this system that holds your place in line and calls you when an agent is available. Check out how it works here: https://youtu.be/_kiP6q8DX5c The HMRC person told me that since I was physically operating from Germany, I needed to pay personal income tax there, but my UK company still had corporate tax obligations in the UK. Saved me from making a huge mistake.
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Evan Kalinowski
•Wait, how does this actually work? Do they just call the tax office for you? Seems too good to be true considering how impossible it is to reach anyone at tax departments.
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Victoria Charity
•This sounds like a scam tbh. Why would I pay someone else to call the tax office when I can just keep trying myself? Not to mention giving all my info to some random service.
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The Boss
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Victoria Charity
OK I need to eat my words from earlier. I was super skeptical about that Claimyr thing, but my accountant actually recommended it too so I gave it a shot last week when I needed to talk to HMRC about my overseas situation. Got through to an actual human at HMRC in about 30 minutes when I'd been trying for literally weeks on my own. The agent walked me through exactly what forms I needed for my dual-country setup. Honestly shocked that it worked as advertised.
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Jasmine Quinn
An important factor nobody's mentioned yet - check if there's a tax treaty between the UK and New Zealand! This can make a huge difference in avoiding double taxation. Usually these treaties have specific provisions for determining where a company is considered resident for tax purposes when there's ambiguity like in your situation.
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Oscar Murphy
•Theres also something called a "tie-breaker" rule in most tax treaties that helps determine which country gets primary taxing rights when both claim you. Usually comes down to where you have stronger personal connections, permanent home, etc.
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Jasmine Quinn
•You're absolutely right about the tie-breaker rules. They're crucial in these situations. Most treaties follow a hierarchy of tests: permanent home first, then center of vital interests (personal/economic connections), then habitual abode, and finally nationality. For a company, the tie-breaker often comes down to where the effective management is located - which in the original poster's case would likely be New Zealand since that's where the actual decision-makers are physically located, regardless of where the company is registered.
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Nora Bennett
Get ready for a paperwork nightmare! I have a similar US/UK situation and end up filing in both countries. The key is finding a good accountant who specializes in international taxation - don't try to DIY this!!
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Ryan Andre
•How much does an international tax accountant usually cost? I'm in a similar boat with income from three different countries and I'm terrified of getting it wrong, but also worried about the cost.
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