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...
There are several administrative matters and deadlines to be aware of in connection with diverted profits tax (DPT), which is unsurprising given that DPT is an entirely...
A company doing business in the UK may initially undertake activities without a taxable presence in the UK.However, where activities will actually be undertaken in the...
BackgroundIt was announced at Autumn Statement 2014 that a new tax would be introduced, known as the diverted profits tax (DPT) (see the Autumn Statement 2014 ― corporate...
IntroductionThis guidance note outlines the three main tax considerations when a UK company makes an acquisition outside the UK, which are:•structure, ie whether to...
Direct earningsForeign source trading income of a UK company earned directly (where trading with a country) is taxed in the UK as trading income of the company, after...
Calculation of the effective tax rateAn international group’s effective rate of tax is usually calculated as the amount of tax it pays divided by its consolidated...
Reasons for an inbound migrationMigration describes the situation when a company changes its tax residence. A company which is not incorporated in the UK may become...
What is country-by-country reporting?Country-by-country (CbC) reporting essentially requires large multinational enterprises (MNEs) to provide an annual return that...
Common situationsInternational tax is relevant to a number of different situations. This guidance note outlines the most common situations. Also see the Glossary for...
This note has been updated for HMRC’s guidance published in December 2018, which supersedes HMRC’s interim guidance published in March 2015 and updated in November...
There are several administrative matters and deadlines to be aware of in connection with diverted profits tax (DPT), which is unsurprising given that DPT is an entirely...
A company doing business in the UK may initially undertake activities without a taxable presence in the UK.However, where activities will actually be undertaken in the...
BackgroundIt was announced at Autumn Statement 2014 that a new tax would be introduced, known as the diverted profits tax (DPT) (see the Autumn Statement 2014 ― corporate...
IntroductionThis guidance note outlines the three main tax considerations when a UK company makes an acquisition outside the UK, which are:•structure, ie whether to...
Direct earningsForeign source trading income of a UK company earned directly (where trading with a country) is taxed in the UK as trading income of the company, after...
Calculation of the effective tax rateAn international group’s effective rate of tax is usually calculated as the amount of tax it pays divided by its consolidated...
Reasons for an inbound migrationMigration describes the situation when a company changes its tax residence. A company which is not incorporated in the UK may become...
What is country-by-country reporting?Country-by-country (CbC) reporting essentially requires large multinational enterprises (MNEs) to provide an annual return that...
Common situationsInternational tax is relevant to a number of different situations. This guidance note outlines the most common situations. Also see the Glossary for...
This note has been updated for HMRC’s guidance published in December 2018, which supersedes HMRC’s interim guidance published in March 2015 and updated in November...
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