International

International guidance:

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note explains: • the general concept of controlled foreign company (CFC) rules • the...

Practice Note

ARCHIVED: This Practice Note has been archived and is not maintained. Thin capitalisation and transfer pricing are related but slightly different concepts. Some consider...

Practice Note

This Practice Note outlines the key administrative obligations, including the due date for: • submitting information returns, and • paying the tax to HMRC in respect of...

Practice Note

What are the anti-avoidance concerns in a double tax treaty context? As discussed in Practice Note: What are double tax treaties?, one of the aims of double tax...

Practice Note

For more information on the other types of exemptions and reliefs from UK withholding tax that are available, see Practice Note: Exemptions and reliefs from UK...

Practice Note

Why is assistance in collection needed? The background to this topic is the existence of a general rule of international law concerning the fact that generally one...

Practice Note

The exchange of information between HMRC and tax authorities in other territories is an essential tool in enabling authorities both to administer and enforce their own...

Practice Note

The Common Reporting Standard (CRS) is a global standard under which participating jurisdictions agree to exchange information about financial accounts held by...

Practice Note

This Practice Note explains the concept of branch incorporation relief, which is available under UK domestic law in respect of: • corporation tax on chargeable gains, and...

Practice Note

This Practice Note deals with the controlled foreign company (CFC) rules that apply for accounting periods of CFCs commencing on or after 1 January 2013. For a Practice...

Practice Note

This Practice Note deals with the new controlled foreign company (CFC) rules that apply for accounting periods of CFCs that start on or after 1 January 2013. The...

Practice Note

This Practice Note deals with the new controlled foreign companies (CFC) rules that apply for accounting periods of CFCs commencing on or after 1 January 2013. For more...

Practice Note

This Practice Note deals with the controlled foreign company (CFC) rules that apply for accounting periods of CFCs starting on or after 1 January 2013. As explained in...

Practice Note

This Practice Note deals with the controlled foreign company (CFC) rules that apply for accounting periods of CFCs starting on or after 1 January 2013. As explained in...

Practice Note

This Practice Note deals with the controlled foreign company (CFC) rules that apply for accounting periods of CFCs starting on or after 1 January 2013. As explained in...

Practice Note

This Practice Note deals with the controlled foreign company (CFC) rules that apply for accounting periods of CFCs starting on or after 1 January 2013. Chapter 9 of Part...

Practice Note