The following Corporation Tax guidance note Produced by Tolley in association with Anne Fairpo provides comprehensive and up to date tax information covering:
The UK has three options for providing relief from double taxation: two via credit relief and one by way of deduction from the profits of the business.
The UK has more than 130 tax treaties, which may exempt income from tax in one country or give credit for foreign taxes suffered on income. The precise mechanism will vary from treaty to treaty. Treaty relief takes precedence over other forms of relief for foreign taxes. For details on tax treaties, see the Structure of a tax treaty guidance note.
To claim treaty relief, the taxpayer must have been resident in the UK throughout the chargeable period. Residence for these purposes is defined by UK law, not by the relevant treaty. See the Residence of companies guidance note.
A non-resident company with a UK permanent establishment can claim treaty relief on the same basis as is available to a UK company. However, the total relief is not to exceed what would have been available if the permanent establishment had been an entity resident in the UK. See the Permanent establishment guidance note.
The UK also unilaterally allows foreign tax paid as a credit against the UK tax liability on the same income.
This is useful where either there is no tax treaty with the jurisdiction of payment, or where the tax treaty does not cover the particular type of tax (such as local taxes).
Treaty relief and unilateral relief are both given by way of credit. Where credit is g
**Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason.
Access this article and thousands of others like it free for 7 days with a trial of TolleyGuidance.
Read full article
Already a subscriber? Login
IntroductionUK tax must be withheld on UK payments including:•interest•royalties•rental incomeWithholding tax may be reduced under double tax treaties (DTT) or European directives, both of which may be subject to making a formal claim.This guidance note outlines the rules for UK withholding tax, and
This guidance note explains how to calculate the amount of tax that arises under the lifetime charge. In general terms the lifetime charge will apply to individuals who transfer property into a trust that is subject to the relevant property regime. See the Chargeable transfers and Occasions of
Business asset disposal relief (previously known as entrepreneurs’ relief) is a capital gains tax (CGT) relief that allows business owners with chargeable gains on qualifying business assets to pay CGT at a rate of 10%. For disposals made on or after 11 March 2020, the relief is available on up to
Preparatory workBefore completing the Inheritance Tax account for submission to HMRC, the practitioner needs to undertake a comprehensive review of the extent of the estate and its proposed distribution. The work required leading up to the submission of the account is described in detail in the
To view our latest tax guidance content, sign in to Tolley Guidance or register for a free trial.