The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
Certain double tax treaty provisions contain anti-conduit conditions, which deny treaty benefits where amounts received are paid on to another company.
An arm’s length price is the price which would be charged between unconnected parties. See the Transfer pricing rules ― overview guidance note.
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.
The OECD Base Erosion and Profit Shifting (BEPS) initiative is considering a number of measures to combat perceived international tax avoidance.
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.
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) 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 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 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.
A deemed capital contribution can arise where the value of a company
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‘Hold-over’ relief allows for the deferral of a gain that would otherwise arise in relation to a disposal. No capital gains tax (CGT) is due in respect of the disposal, but the base cost of the asset for the transferee for the purpose of a future disposal is reduced by an amount equal to the gain
The majority of state benefits (also called social security benefits) are managed by the Department of Work and Pensions (DWP) via the Jobcentre Plus.Some benefits are dependent on a national insurance contribution record (and different classes of national insurance provide different benefit
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
Income and gains may be taxable in more than one country. The UK has three ways of ensuring that the individual does not bear a double burden:1)treaty tax relief may reduce or eliminate the double tax 2)if there is no treaty, the individual can claim ‘unilateral’ relief by deducting the foreign tax
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