The following Tax guidance note Produced in partnership with Jeremy Cape and Robert O'Hare of Squire Patton Boggs (UK) LLP provides comprehensive and up to date legal information covering:
Many UK companies operate entirely within the boundaries of the UK, with all of their customers and suppliers being based in the UK, such that all of the company's profits and gains are generated by activity in the UK. However, not all UK resident companies do so and for quite a large population of UK companies their profits include non-UK profits. These companies therefore have to consider the interaction of:
the UK principle of taxing worldwide profits, for which see more below, and
the tax systems of other territories
This population of UK resident companies with non-UK profits is not limited to large multinational groups but includes any company that suffers foreign tax, whether by way of:
withholding tax on payments received, and/or
tax due by direct assessment in a foreign territory that imposes tax on the activity of the UK resident company, whether or not the non-UK activities constitute a permanent establishment (PE)
This note sets out a brief summary of the key issues a UK resident company with foreign profits would have to consider with regard to the scope of UK corporation tax and the foreign tax relief available to it, assuming that it has not made an election to exempt its foreign branch profits, which is explained further in Practice Note: Structure of the foreign branch exemption.
**excludes LexisPSL Practice Compliance, Practice Management and Risk and Compliance. To discuss trialling these LexisPSL services please email customer service via our online form. Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason. Trial includes one question to LexisAsk during the length of the trial.
To view the latest version of this document and thousands of others like it, sign-in to LexisPSL or register for a free trial.
Existing user? Sign-in
Take a free trial
Take a free trial
0330 161 1234