Commentary

D4.803A Classification of foreign entities

Corporate tax
Corporate tax | Commentary

D4.803A Classification of foreign entities

Corporate tax | Commentary

D4.803A Classification of foreign entities

The provisions in this article apply where an election has not been made for exemption for the profits of a foreign permanent establishment (D4.801).

Entities are classified as either fiscally 'transparent' or 'opaque' solely for the purposes of deciding how a member is to be taxed on the income they derive from their interest in the entity.

When considering the classification of a foreign entity (ie whether it is either opaque or transparent) for UK tax purposes, HMRC have issued specific guidance1. Where clarification is sought in relation to a foreign entity HMRC will attempt to give

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