Commentary

D1.365 Securities free of tax to residents abroad (FOTRA)

Corporate tax
Corporate tax | Commentary

D1.365 Securities free of tax to residents abroad (FOTRA)

Corporate tax | Commentary

Income that is exempted from corporation tax

D1.365 Securities free of tax to residents abroad (FOTRA)

FOTRA securities are securities 'free of tax to residents abroad'. Broadly, these are United Kingdom government securities that are beneficially owned by persons who are not resident in the UK. There are three types of FOTRA security, each with an 'exemption condition'. The exemption condition depends on the nature of the FOTRA security1. For the purposes of the exemptions, a FOTRA security means2:

  1.  

    •     a security issued with a condition about exemption from taxation authorised by F(No 2)A 1931, s 22

  2.  

    •     a

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