UK taxation of foreign permanent establishments

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Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
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
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
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
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
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
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
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 taxation of foreign permanent establishments content

Practice notes
Why are special rules required to deal with historic losses?As further explained in Practice Note: UK taxation of foreign profits in a UK resident...
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9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.This note deals only with the anti-diversion rule that has effect for accounting...
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9th Apr
Practice notes
This note only deals with the foreign branch exemption anti-diversion rules that apply to accounting periods commencing on or after 1 January 2013.For...
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9th Apr
Practice notes
As explained in Practice Note: Foreign branch exemption—structure of the foreign branch exemption, the concept of the foreign permanent establishments...
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25th Feb
Practice notes
Purpose of the regimeThe purpose of the foreign branch exemption is to exempt from UK corporation tax the profits of the worldwide permanent...
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24th Feb
Practice notes
As explained in Practice Note: Foreign branch exemption—foreign permanent establishments amount there are a number of rules that must be followed in...
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24th Feb
Practice notes
This Practice Note only describes the foreign branch exemption anti-diversion rules that apply to accounting periods commencing on or after 1 January...
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24th Feb
Practice notes
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...
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24th Feb
Practice notes
This Practice Note only describes the foreign branch exemption anti-diversion rules that apply to accounting periods commencing on or after 1 January...
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23rd Feb

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