Treaty non resident company and corporation tax

Although a UK incorporated company is typically subject to UK corporation tax at rates of up to 28% it can gain significant advantages if it's treaty resident overseas. Under the provisions a company incorporated in the UK, but qualifying as a resident of some other country for the purposes of a tax treaty, is to be treated for UK tax purposes as not UK resident. This is clearly very attractive in terms of UK tax, as a non resident company would be exempt from UK tax on gains as well as overseas income. In terms of overseas tax you'd need to ensure that the treaty was with a country that taxed the company profits at low or nil rates eg:

A company incorporated in the UK but resident in Mauritius may have a tax rate as low as 1.5%.

A company resident in Singapore will pay no tax on any of its foreign income,

A company resident in Malaysia will be exempt from tax on most foreign income

A company resident in Barbados will pay local tax on its foreign income only if it remits income to Barbados. None of these countries levy any tax on capital gains. Therefore a UK incorporated company treaty resident in a suitable jurisdiction can have the best of both worlds.