Commentary

D4.936 Tax sparing relief

Corporate tax
Corporate tax | Commentary

D4.936 Tax sparing relief

Corporate tax | Commentary

D4.936 Tax sparing relief

FA 2009 introduced the exempt distribution regime which broadly provides that most dividends received by a UK company on or after 1 July 2009 (from the UK or overseas) will be exempt from corporation tax (see Division D5.1). The provisions discussed in this article apply to overseas dividends received on or after 1 July 2009 that are not exempt and all other overseas dividends received before 1 July 2009.

The general outline of tax sparing provisions (pioneer relief) in certain overseas countries and UK tax sparing relief is discussed at E6.432A. The country granting pioneer relief may make it a condition of obtaining the relief that the investment is made through a locally incorporated subsidiary. In the case of a UK group of companies investing through such a vehicle, the profits will be subject to UK corporation tax either when

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial