Tax situation

Hi All,

Perhaps someone could shed any light on a situation; its a bit complicated.

My friend owns 50% of a UK company and pays himself a minimum wage and lives off dividend payments. His tax bill last year was only about £5.5K, he takes the personal tax allowance and the rest as dividends. This is all very normal for UK company directors.

My friend is due to set up a Maltese company as a off-shoot of the parent company in order to employ locals ( its an internet based company and the staff in Malta would be cheaper in comparison to the UK).  Sometime after setting up this company he intends to relocate to Malta to have a personal presence in the Malta office, whilst continuing to travel regularly to the UK (perhaps 50-100 days per year out of Malta.

I have been told that some off the profit (income) of the UK based company could effectively be transfered to Maltese company to profit from paying only 5% corporate tax versus a higher rate in the UK.

My friends is income is enough to be considered under the HNWI scheme, although it would make no sense as it would mean an increase in the amount of tax liable - which isn't really the objective of the scheme.

What would the best way of structuring all of that? Who would be able to tell me?