Hence the executives/boardmembers-all-fly-to-some-island (Jersey is the one in my mind), have board meeting in the airport, sign the papers, and all fly home?
Company stays "in" Jersey, none of the humans need to live there?
Company stays "in" Jersey, none of the humans need to live there?
So if 50% or more of your directors spend 183 days per year in the UK then your Estonian based business becomes UK tax resident in the eyes of the UK.
Do not underestimate the complexity of these rules.