Corporation Tax Guidance
IntroductionThis guidance note outlines the tax considerations when a foreign company makes a loan to a UK company.An overseas...
IntroductionA company that is not resident in the UK will only be subject to UK corporation tax if it carries on a trade in the UK...
Reasons for an outbound migrationMigration describes the situation when a company changes its tax residence. Some companies...
The UK transfer pricing rules require an adjustment of profits where a transaction between connected parties is not undertaken at arm’s length and has...
What is transfer pricing?Transfer pricing is the prices at which an enterprise transfers either physical goods, intangible property or services,...
Transfer pricing rules also apply to financing arrangements so loans between connected companies where one of those companies controls the other, or...
This guidance note explains how UK profits of overseas companies are subject to UK tax. For an overview of how overseas companies can be subject to UK...
A UK company doing business overseas is likely to have to deal with transactions in foreign currencies, leading to foreign exchange movements where...
A UK company expanding overseas may do so in a variety of ways, including:•distance trading from the UK, with no local presence•a branch, which can be...
Evidence to demonstrate arm’s length transfer prices need only be produced at the request of HMRC, but the documentation should be contemporaneous....
Interest charged by a UK company to an overseas borrower may be taxed in the borrower’s country by way of withholding tax. It can be complicated to...
Although a UK company can do a reasonable amount of business in another country without a taxable presence in that country, eventually the company may...
IntroductionThis guidance note outlines the tax considerations when a foreign company makes a loan to a UK company.An overseas company may make a loan...
The UK transfer pricing rules require an adjustment of profits where a transaction between connected parties is not undertaken at arm’s length and has created a potential...
What is transfer pricing?Transfer pricing is the prices at which an enterprise transfers either physical goods, intangible property or services, including financing...
Transfer pricing rules also apply to financing arrangements so loans between connected companies where one of those companies controls the other, or where both are under...
This guidance note explains how UK profits of overseas companies are subject to UK tax. For an overview of how overseas companies can be subject to UK tax, and how tax is...
A UK company doing business overseas is likely to have to deal with transactions in foreign currencies, leading to foreign exchange movements where the transaction is...
A UK company expanding overseas may do so in a variety of ways, including:•distance trading from the UK, with no local presence•a branch, which can be formed with just...
Evidence to demonstrate arm’s length transfer prices need only be produced at the request of HMRC, but the documentation should be contemporaneous. That means that the...
Interest charged by a UK company to an overseas borrower may be taxed in the borrower’s country by way of withholding tax. It can be complicated to determine exactly...
Although a UK company can do a reasonable amount of business in another country without a taxable presence in that country, eventually the company may need to consider...
IntroductionThis guidance note outlines the tax considerations when a foreign company makes a loan to a UK company.An overseas company may make a loan to a UK company in...
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