The following Corporation Tax guidance note by Tolley in association with Robert Langston of Saffery Champness provides comprehensive and up to date tax information covering:
This guidance note outlines the international tax issues a company should consider in advance of its year end.
Certain UK tax reliefs are restricted to transactions between UK group companies; this is arguably contrary to EU law. A group should consider if any (protective) claims or elections should be made in respect of transactions with non-UK group companies.
These may include:
A company can elect for its foreign branches to be exempt from corporation tax. In addition, the losses of exempt branches are not available to set against other profits.
This election is irrevocable and applies to all the foreign branches of a company.
The election must be made before the start of the first accounting period to which it will apply. See INTM281020 for details on the required form and information for the election.
The benefit of an election will depend on:
If significant losses are anticipated, then a branch exemption election may not be beneficial as these losses would not be available to set against UK profits of the company.
If the overseas
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