Corporation Tax Guidance

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International tax and transfer pricing

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Latest Guidance
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1 Jul 2019

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...

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1 Jul 2019

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...

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1 Jul 2019

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...

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1 Jul 2019

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...

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1 Jul 2019

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...

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1 Jul 2019

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...

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28 Jun 2019

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...

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28 Jun 2019

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....

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28 Jun 2019

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...

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28 Jun 2019

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...

Latest Guidance
Corporation_tax_img2
Corporation Tax

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...

Corporation_tax_img
Corporation Tax

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...

Corporation_tax_img6
Corporation Tax

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...

Corporation_tax_img5
Corporation Tax

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...

Corporation_tax_img7
Corporation Tax

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...

Corporation_tax_img9
Corporation Tax

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...

Corporation_tax_img6
Corporation Tax

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...

Corporation_tax_img10
Corporation Tax

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....

Corporation_tax_img9
Corporation Tax

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...

Corporation_tax_img9
Corporation Tax

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...