Glossary

Produced by Tolley
Glossary

The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Glossary
  • Anti-conduit
  • Arm’s length price
  • Beneficial ownership
  • BEPS
  • Branch
  • Capital contribution
  • Controlled foreign company (CFC)
  • Credit relief
  • Deduction relief
  • More...

Anti-conduit

Certain double tax treaty provisions contain anti-conduit conditions, which deny treaty benefits where amounts received are paid on to another company.

Arm’s length price

An arm’s length price is the price which would be charged between unconnected parties. See the Transfer pricing rules ― overview guidance note.

Beneficial ownership

A company does not have beneficial ownership of income if it is required to pay it on to another company, eg if it receives the income as a nominee.

BEPS

The OECD Base Erosion and Profit Shifting (BEPS) initiative is considering a number of measures to combat perceived international tax avoidance.

Branch

A branch is an establishment of a company outside the country in which it is incorporated. Unlike a subsidiary company, it does not usually have separate legal personality, but it may need to be registered. See the Permanent establishment guidance note.

Capital contribution

In some countries, it is possible to make a capital contribution to a company, which increases its assets without increasing its share capital.

Controlled foreign company (CFC)

Controlled foreign company (CFC) rules are anti-avoidance rules which tax the profits of subsidiaries in their parent companies. See the Controlled foreign companies (CFCs) guidance note.

Credit relief

Credit relief is a form of double tax relief where the tax a company pays in the country where it is resident is reduced by overseas tax which it has suffered. See the Double tax relief guidance note.

Deduction relief

Deduction relief is a form of double tax relief where the taxable profits of a company are reduced by overseas tax which it has suffered. See the Double tax relief guidance note.

Deemed capital contribution

A deemed capital contribution can arise where the value of a company

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