Entity classification

Entity classification guidance:

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

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

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