UK company residence

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Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
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...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent UK company residence content

Practice notes
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...
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9th Apr
Practice notes
A company is UK tax resident if it is:•incorporated in the UK (subject to exceptions), or•centrally managed and controlled in the UKprovided it is not...
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4th Apr
Q&As
Any restrictions on travel imposed by the coronavirus (COVID-19) may impact on corporate tax residency if businesses do not take care to recognise the...
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Produced in partnership with Martin Shah 15th Feb
Q&As
It is possible for a non-UK incorporated company to redomicile to the UK. Depending on what is permitted under the laws of the non-UK company’s...
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9th Feb
Q&As
Companies HouseThe statutory rules in relation to overseas companies are set out in Part 34 of the Companies Act 2006 (CA 2006) and the Overseas...
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9th Feb
Precedents
1Company's tax residence1.1[Insert name of the company] (the Company) is resident in [insert name of the jurisdiction in which the company is intended...
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26th Jan
Q&As
Whether a single employee working in the UK for a non-UK company could give rise to a taxable presence for the non-UK company is considered below.Risk...
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8th Dec
Q&As
Before introducing a non-UK tax resident individual as a director of a UK company, the company should obtain advice from UK and non-UK tax advisers to...
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29th Nov
Q&As
Where a non-UK company is transferred to a UK incorporated and tax-resident company by way of a share for share exchange, there are numerous potential...
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26th Nov
Precedents
1 Authority of directors The business of the company shall be managed by the directors, who may exercise all such powers of...
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26th Sep

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