Year end international planning

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Year end international planning

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

This guidance note outlines the international tax issues a company should consider in advance of its year end.

Branch exemption

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.

It should be noted that the Government has announced that the foreign permanent establishment (PE) exemption will become mandatory for accounting periods beginning on or after 1 January 2027.

The benefit of an election will depend on:

  1. whether losses may arise in the future in the company’s foreign branches

  2. the rate of overseas tax which is paid on the profits of the foreign branches

If significant losses are anticipated then a branch exemption election may not be beneficial

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Powered by Tolley+
  • 20 Aug 2026 13:00

Popular Articles

Payments on account (POA)

Payments on account (POA)This guidance note provides and overview of the payments on account regime (POA). More in depth commentary can be found in De Voil Indirect Tax Service V5.110.What are payments on account?VAT registered businesses with an annual VAT liability of more than £2.3m are required

14 Jul 2020 12:52 | Produced by Tolley Read more Read more

Overseas property businesses for companies

Overseas property businesses for companiesOverviewReal estate income is generally taxed where the property is located; the UK tax treaties generally allow the jurisdiction where the land is located to tax income from the land.Therefore, a UK company with overseas property may be subject to tax in

14 Jul 2020 12:22 | Produced by Tolley in association with Rob Durrant-Walker of Crane Dale Tax, part of AMS Group Read more Read more

Capital allowances on cars

Capital allowances on carsSummary of capital allowances on carsThe current capital allowance rates applicable to cars are as follows:Pool typeDescription of carRateLegislationMain rate poolNew and unused cars with CO2 emissions of 50g/km and below 18%CAA 2001, s 104AASecondhand cars with CO2

14 Jul 2020 11:08 | Produced by Tolley Read more Read more