Offshore companies

Offshore companies guidance:

This Practice Note is about the rules that can impose a charge to tax on UK persons holding interests in a non-UK resident company if that company disposes of an asset...

Practice Note

The capital gains legislation includes specific provisions for persons who are connected with one another. These provisions can be divided into two broad groups: • rules...

Practice Note

What is a Cayman Islands foundation company? The Foundation Companies Law, 2017 came into force on 19 October 2017, enabling the establishment of foundation companies...

Practice Note

Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has entered an...

Practice Note

It is necessary to characterise overseas entities for UK tax purposes, as this will determine how they (and their members and potentially other persons connected with...

Practice Note

This guide sets out the requirements for executing deeds in various international jurisdictions. The table provides a quick-reference summary of the execution formalities...

Practice Note

This Practice Note discusses the two ‘failure to prevent’ corporate criminal offences created by the Criminal Finances Act 2017 (CFA 2017): • CFA 2017, s 45 creates the...

Practice Note

The fact that an overseas company is a seller, buyer, landlord, tenant, guarantor or mortgagee in relation to the sale or leasing of land in England and Wales does not...

Practice Note

This Practice Note explains the rules that apply to distributions made to UK resident and domiciled individuals on or after 6 April 2016. The way in which individuals are...

Practice Note

ARCHIVED: This Practice Note has been archived and is not maintained. The way in which individuals are taxed on distributions was substantially changed in Finance Act...

Practice Note

When looking at the definition of chargeable transfers and transfers of value in the Inheritance Tax Act 1984 (IHTA 1984), it is perhaps not immediately apparent that...

Practice Note

This Practice Note summarises the changes to the excluded property rules from 6 April 2017 introduced by the Finance (No 2) Act 2017 (F(No 2)A 2017). Under the changes,...

Practice Note

An opinion letter should be obtained in respect of every transaction in Great Britain with a foreign company eg a sale or purchase, a security transaction, a...

Practice Note

A legal opinion should be obtained in respect of any property transaction in England and Wales entered into with an overseas company; for example, the sale or purchase of...

Practice Note

ARCHIVED: This Practice Note gives an overview of the non-resident capital gains tax (NRCGT) charge that applied to certain non-UK resident persons when they disposed of...

Practice Note

STOP PRESS: Following consultation, amendments have been made to the UK rules taxing offshore receipts in respect of intangible property (ORIP) by The Income Tax (Trading...

Practice Note

The concept of ordinary share capital is important for UK tax purposes. This Practice Note sets out the key tax reliefs that require ordinary share capital (whether...

Practice Note

This Practice Note considers shadow directors of offshore companies and the extent to which such directors may be subject to benefit in kind charges arising under the...

Practice Note

Summary of tax considerations The concept of a close company is intended to capture those companies that are closely controlled (ie by the owners and managers) and...

Practice Note

Each jurisdiction applies its own domestic law test to determine when a company is treated as tax resident there. A company can be resident in more than one jurisdiction,...

Practice Note

An overseas entity may be characterised for UK tax purposes as transparent or opaque. This Practice Note explains how such classification will affect how the entity is...

Practice Note

This Practice Note looks at the meaning of a permanent establishment (PE) for tax purposes, both under UK domestic law and in double tax treaties. The UK tax treatment of...

Practice Note

A company is UK tax resident if it is: • incorporated in the UK (subject to exceptions), or • centrally managed and controlled in the UK provided it is not treated as...

Practice Note

FORTHCOMING CHANGE relating to UK property business and non-UK resident companies: From 6 April 2020, non-UK resident companies will be brought into the charge to...

Practice Note
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