The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
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 where the interest has arisen for tax purposes, but the UK tax treaties generally determine the interest to arise in the country where the recipient of the interest is resident (or where it has a permanent establishment if the interest is attributable to the PE).
The amount of withholding tax will depend on the jurisdiction of payment and whether there is a tax treaty with the UK. Where withholding ta
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The substantial shareholding exemption (SSE) provides a complete exemption from the liability to corporation tax on the gains generated from qualifying disposals of shares and interests in shares by qualifying companies. Conversely, if losses are generated by the disposal and the SSE conditions are
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
The basic rule is that all benefits provided to an employee by reason of their employment are taxable unless there is a specific exemption or other rule that means they are not chargeable to tax.ExemptionsThe main exemptions for employee benefits are in ITEPA 2003, ss 227–326B (Pt 4).Below is an
Time for paymentTwo statutory rules apply on death:•tax is ‘due’ six months after the end of the month of death and carries interest from the ‘due’ date until paidThere is a possibility of payment by instalments, but this applies to certain types of property only ― see the ‘Availability of
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