The following Corporation Tax guidance note Produced by Tolley in association with Anne Fairpo provides comprehensive and up to date tax information covering:
The treatment of losses of UK companies from foreign operations depends on the nature of the foreign operations.
Losses of a UK company from a trade carried on wholly overseas by that company cannot be set against any profits from other sources, including other overseas businesses. The losses can only be carried forward and set against future profits of the same trade. This rule was not relaxed by the changes in the utilisation of losses carried forward arising from 1 April 2017 which apply for UK trading losses. These amendments allow other trade losses carried forward to be offset against future profits or surrendered as group relief. For details of the rules on carrie
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Almost all companies will have some loan relationships. However, some items that are commonly assumed to be loan relationships are not (eg outstanding consideration for the sale / purchase of property and inter-company balances relating to unpaid amounts for goods or services, in each case where
If the taxpayer does not have sufficient information to enable them to complete the tax return in the time allowed, they should include either a best estimate or a provisional figure. The taxpayer should not either leave a box blank or enter ‘details to follow’ as HMRC will regard this as an
What is a quoted company?Reference to a quoted company is usually to a company where the shares in the company are listed on the London Stock Exchange, any other international stock exchange, or on AIM or ICAP Securities and Derivatives Exchange (formerly the PLUS market and now known as ISDX) in
This guidance note considers the capital gains tax implications where shares are sold in exchange for new shares.The consideration paid by a purchasing company to the shareholder(s) for their shares in a target company could be in the form of either:•new shares in the purchasing company in exchange