Corporation Tax Guidance

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International tax and transfer pricing

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Latest Guidance
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27 Jun 2019

IntroductionThere are a number of occasions when it is necessary to consider the location for a holding company, including:•migration or redomiciliation of an existing...

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27 Jun 2019

Loans between associated companies where one of those companies controls the other, or where both are under common control, are subject to the transfer pricing rules.A...

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27 Jun 2019

The UK transfer pricing rules require an adjustment of profits where a transaction between connected parties is not undertaken at arm’s length and has created a potential...

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27 Jun 2019

Where a UK company receives royalties, the company may suffer withholding tax in the jurisdiction where the payments are made. The level of withholding tax will depend on...

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27 Jun 2019

The UK has three options for providing relief from double taxation: two via credit relief and one by way of deduction from the profits of the business.Credit reliefTax...

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27 Jun 2019

Arm’s length principleThe arm’s length principle is generally applied by comparing a controlled transaction (ie the transaction between the connected parties) with...

Corporation_tax_img8
27 Jun 2019

This note has been updated in line with HMRC’s guidance  published in December 2018, which supersedes HMRC’s interim guidance published in March 2015 and updated in...

Latest Guidance
Corporation_tax_img5
Corporation Tax

IntroductionThere are a number of occasions when it is necessary to consider the location for a holding company, including:•migration or redomiciliation of an existing...

Corporation_tax_img3
Corporation Tax

Loans between associated companies where one of those companies controls the other, or where both are under common control, are subject to the transfer pricing rules.A...

Corporation_tax_img2
Corporation Tax

The UK transfer pricing rules require an adjustment of profits where a transaction between connected parties is not undertaken at arm’s length and has created a potential...

Corporation_tax_img6
Corporation Tax

Where a UK company receives royalties, the company may suffer withholding tax in the jurisdiction where the payments are made. The level of withholding tax will depend on...

Corporation_tax_img9
Corporation Tax

The UK has three options for providing relief from double taxation: two via credit relief and one by way of deduction from the profits of the business.Credit reliefTax...

Corporation_tax_img5
Corporation Tax

Arm’s length principleThe arm’s length principle is generally applied by comparing a controlled transaction (ie the transaction between the connected parties) with...

Corporation_tax_img8
Corporation Tax

This note has been updated in line with HMRC’s guidance  published in December 2018, which supersedes HMRC’s interim guidance published in March 2015 and updated in...