Foreign branch exemption ― overview

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Foreign branch exemption ― overview

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

The UK provides an elective exemption from UK corporation tax for the profits of an overseas permanent establishment (PE) of a UK company (other than certain insurance companies). The term ‘foreign permanent establishment’ (foreign PE) is used in UK tax law to refer to those overseas operations of a company which were previously described as a ‘branch’.

The Government has published a policy paper, draft legislation and an explanatory note providing for the exemption to become mandatory for UK resident companies. The changes will generally apply for accounting periods beginning on or after 1 January 2027. The draft legislation also includes provisions intended to prevent companies delaying the commencement of the mandatory regime by using short accounting periods.

Under the proposed transitional rules, losses and other amounts attributable to a foreign PE arising before the exemption becomes mandatory will generally not be available to be carried forward to post-transition periods. The existing legislation (see below) taxing profits of an exempted foreign PE where there is a ‘total opening negative amount’ will be repealed. Targeted

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Powered by Tolley+™

Popular Articles

Bad debts

Bad debtsBad debts usually arise where goods or services have been provided to a customer, for which payment has not been received within a reasonable or specified time period, or for which the customer is unable to pay. It is necessary to determine the quantum of relief that can be claimed for bad

14 Jul 2020 15:34 | Produced by Tolley Read more Read more

Research and development expenditure credit (RDEC)

Research and development expenditure credit (RDEC)This guidance note provides information on how research and development expenditure credits (RDEC) are calculated and utilised. The Qualifying expenditure for R&D tax relief guidance note provides information on what expenditure qualifies for

14 Jul 2020 13:24 | Produced by Tolley in association with Will Sweeney Read more Read more

Corporate interest restriction ― administrative aspects

Corporate interest restriction ― administrative aspectsThe corporate interest restriction (CIR) regime has some specific administrative rules in addition to the general administrative requirements for corporation tax returns. This guidance note does not include commentary on provisions that are

14 Jul 2020 11:19 | Produced by Tolley Read more Read more