Corporation Tax Guidance

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International tax and transfer pricing

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Latest Guidance
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13 Mar 2020

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...

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13 Mar 2020

What is transfer pricing?Transfer pricing is the prices at which an enterprise transfers either physical goods, intangible property or services,...

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13 Mar 2020

Transfer pricing rules also apply to financing arrangements so loans between connected companies where one of those companies controls the other, or...

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1 Jul 2019

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...

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1 Jul 2019

A UK company doing business overseas is likely to have to deal with transactions in foreign currencies, leading to foreign exchange movements where...

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1 Jul 2019

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...

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1 Jul 2019

Evidence to demonstrate arm’s length transfer prices need only be produced at the request of HMRC, but the documentation should be contemporaneous....

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1 Jul 2019

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...

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1 Jul 2019

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...

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28 Jun 2019

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...

Latest Guidance
Corporation_tax_img10
Corporation Tax

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...

Corporation_tax_img
Corporation Tax

What is transfer pricing?Transfer pricing is the prices at which an enterprise transfers either physical goods, intangible property or services, including financing...

Corporation_tax_img3
Corporation Tax

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...

Corporation_tax_img2
Corporation Tax

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...

Corporation_tax_img
Corporation Tax

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...

Corporation_tax_img6
Corporation Tax

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...

Corporation_tax_img5
Corporation Tax

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...

Corporation_tax_img7
Corporation Tax

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...

Corporation_tax_img9
Corporation Tax

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...

Corporation_tax_img6
Corporation Tax

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...