Corporation Tax Guidance
IntroductionThis guidance note outlines the tax considerations when a foreign company makes a loan to a UK company.An overseas...
IntroductionA company that is not resident in the UK will only be subject to UK corporation tax if it carries on a trade in the UK...
Reasons for an outbound migrationMigration describes the situation when a company changes its tax residence. Some companies...
This guidance note explains how UK profits of overseas companies are subject to UK tax. For an overview of how overseas companies can be subject to UK tax, and how tax is...
A UK company doing business overseas is likely to have to deal with transactions in foreign currencies, leading to foreign exchange movements where the transaction is...
A UK company expanding overseas may do so in a variety of ways, including:•distance trading from the UK, with no local presence•a branch, which can be formed with just...
Evidence to demonstrate arm’s length transfer prices need only be produced at the request of HMRC, but the documentation should be contemporaneous. That means that the...
Interest charged by a UK company to an overseas borrower may be taxed in the borrower’s country by way of withholding tax. It can be complicated to determine exactly...
Although a UK company can do a reasonable amount of business in another country without a taxable presence in that country, eventually the company may need to consider...
IntroductionThis guidance note outlines the tax considerations when a foreign company makes a loan to a UK company.An overseas company may make a loan to a UK company in...
IntroductionA company that is not resident in the UK will only be subject to UK corporation tax if it carries on a trade in the UK through a permanent establishment....
Reasons for an outbound migrationMigration describes the situation when a company changes its tax residence. Some companies migrate from the UK overseas as a way of...
Anti-conduitCertain double tax treaty provisions contain anti-conduit conditions, which deny treaty benefits where amounts received are paid on to another company.Arm’s...
This guidance note explains how UK profits of overseas companies are subject to UK tax. For an overview of how overseas companies can be subject to UK tax, and how tax is...
A UK company doing business overseas is likely to have to deal with transactions in foreign currencies, leading to foreign exchange movements where the transaction is...
A UK company expanding overseas may do so in a variety of ways, including:•distance trading from the UK, with no local presence•a branch, which can be formed with just...
Evidence to demonstrate arm’s length transfer prices need only be produced at the request of HMRC, but the documentation should be contemporaneous. That means that the...
Interest charged by a UK company to an overseas borrower may be taxed in the borrower’s country by way of withholding tax. It can be complicated to determine exactly...
Although a UK company can do a reasonable amount of business in another country without a taxable presence in that country, eventually the company may need to consider...
IntroductionThis guidance note outlines the tax considerations when a foreign company makes a loan to a UK company.An overseas company may make a loan to a UK company in...
IntroductionA company that is not resident in the UK will only be subject to UK corporation tax if it carries on a trade in the UK through a permanent establishment....
Reasons for an outbound migrationMigration describes the situation when a company changes its tax residence. Some companies migrate from the UK overseas as a way of...
Anti-conduitCertain double tax treaty provisions contain anti-conduit conditions, which deny treaty benefits where amounts received are paid on to another company.Arm’s...
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