The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:
Certain double tax treaty provisions contain anti-conduit conditions, which deny treaty benefits where amounts received are paid on to another company.
An arm’s length price is the price which would be charged between unconnected parties. See the Establishing an arm's length price guidance note.
A company does not have beneficial ownership of income if it is required to pay it on to another company, eg if it receives the income as a nominee.
The OECD Base Erosion and Profit Shifting (BEPS) initiative is considering a number of measures to combat perceived international tax avoidance.
A branch is an establishment of a company outside the country in which it is incorporated. Unlike a subsidiary company, it does not usually have separate legal personality, but it may need to be registered. See the Permanent establishment guidance note.
In some countries, it is possible to make a capital contribution to a company, which increases its assets without increasing its share capital.
Controlled foreign company (CFC) rules are anti-avoidance rules which tax the profits of subsidiaries in their parent companies. See the Controlled foreign companies (CFCs) guidance note.
Credit relief is a form of double tax relief where the tax a company pays in the country where it is resident is reduced by overseas tax which it has suffered. See the Double tax relief guidance note.
Deduction relief is a form of double tax relief where the taxable profits of a company are reduced by overseas tax which it has suffered. See
Access this article and thousands of others like it free for 7 days with a trial of TolleyGuidance.
Read full article
Already a subscriber? Login