Corporation Tax Guidance

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International tax and transfer pricing

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Latest Guidance
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28 Jun 2019

IntroductionThe CFC rules as outlined in this note apply to accounting periods beginning on or after 1 January 2013, the date upon which significant changes made by...

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27 Jun 2019

This guidance note outlines some tax considerations in relation to international intellectual property planning. The objective of intellectual property planning is...

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27 Jun 2019

Advance Pricing Agreements (APA)UK companies can agree in advance with HMRC that their transfer pricing method is acceptable for a pre-determined period of time...

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27 Jun 2019

IntroductionTransfer pricing refers to the pricing of goods, services, funds, and tangible and intangible assets transferred within a group, and between connected...

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27 Jun 2019

The references in this note to HMRC guidance have been updated to reflect HMRC’s guidance  published in December 2018. This version supersedes the interim guidance...

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27 Jun 2019

This guidance note outlines how an international corporate structure can affect the tax position of UK resident individuals who are shareholders:•gains made in the...

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27 Jun 2019

IntroductionWhere a corporate borrower other than a financial institution pays interest with a UK source to an overseas lender, then the general rule is that income tax...

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27 Jun 2019

Business restructuringTransfer pricing planning often involves restructuring existing intercompany relationships, so that functions, assets and risks are transferred to...

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27 Jun 2019

IntroductionThis guidance note outlines how a non-UK company may be subject to UK tax. If the company is subject to UK tax, it may have a number of UK filing requirements...

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27 Jun 2019

The references in this note to HMRC’s guidance  on DPT have been updated for the guidance published in December 2018. This supersedes HMRC’s interim guidance published in...

Latest Guidance
Corporation_tax_img
Corporation Tax

IntroductionThe CFC rules as outlined in this note apply to accounting periods beginning on or after 1 January 2013, the date upon which significant changes made by...

Corporation_tax_img7
Corporation Tax

This guidance note outlines some tax considerations in relation to international intellectual property planning. The objective of intellectual property planning is...

Corporation_tax_img9
Corporation Tax

Advance Pricing Agreements (APA)UK companies can agree in advance with HMRC that their transfer pricing method is acceptable for a pre-determined period of time...

Corporation_tax_img2
Corporation Tax

IntroductionTransfer pricing refers to the pricing of goods, services, funds, and tangible and intangible assets transferred within a group, and between connected...

Corporation_tax_img
Corporation Tax

The references in this note to HMRC guidance have been updated to reflect HMRC’s guidance  published in December 2018. This version supersedes the interim guidance...

Corporation_tax_img3
Corporation Tax

This guidance note outlines how an international corporate structure can affect the tax position of UK resident individuals who are shareholders:•gains made in the...

Corporation_tax_img3
Corporation Tax

IntroductionWhere a corporate borrower other than a financial institution pays interest with a UK source to an overseas lender, then the general rule is that income tax...

Corporation_tax_img8
Corporation Tax

Business restructuringTransfer pricing planning often involves restructuring existing intercompany relationships, so that functions, assets and risks are transferred to...

Corporation_tax_img3
Corporation Tax

IntroductionThis guidance note outlines how a non-UK company may be subject to UK tax. If the company is subject to UK tax, it may have a number of UK filing requirements...

Corporation_tax_img3
Corporation Tax

The references in this note to HMRC’s guidance  on DPT have been updated for the guidance published in December 2018. This supersedes HMRC’s interim guidance published in...