My client runs a successful crypto-trading business and would like to cease UK tax residence in order to avoid UK income tax on the profits of the trade. He uses a virtual server in London to ensure he is physically proximate to the crypto exchange. Could this virtual server give him a taxable presence in the UK?
The UK takes a relatively categoric stance that a server physically located in the UK cannot give a person a permanent establishment in the UK. However the limits of this principle have not been tested and as ever the devil is in the detail.
Crypto assets are extremely volatile. The price of a particular asset can change multiple times per second. This volatility creates an opportunity for those traders who are able to execute contracts more quickly than other market participants. In order to capitalise on this opportunity ...
