The following Corporation Tax guidance note Produced by Tolley in association with Anne Fairpo provides comprehensive and up to date tax information covering:
International tax is relevant to a number of different situations. This guidance note outlines the most common situations. Also, see the Glossary guidance note for terms which are frequently encountered when advising on international tax matters.
An overseas company establishing in the UK will need to determine if it has a permanent establishment here and whether it should establish a branch or a subsidiary. See the Setting up in the UK ― branch or subsidiary and Permanent establishment guidance notes.
Any transactions with the subsidiary may be subject to the UK transfer pricing rules. See the Transfer pricing rules ― overview guidance note.
Even without a branch or a subsidiary, there may be withholding tax or UK filing requirements to consider. See the Non-UK companies subject to UK tax guidance note for further details.
From 1 April 2015, the potential application of the diverted profits tax (DPT) will also need to be considered. See the Introduction to the diverted profits tax and related g
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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
Maintenance payments are payments made by a taxpayer to their former or separated spouse for the maintenance of that former spouse or their children. To obtain any tax relief for maintenance payments, one of the couple must have been born before 5 April 1935 and the payments must be made by virtue
What is structures and buildings allowance (SBA)?From 29 October 2018, expenditure on constructing a non-residential building or structure, or in certain cases, expenditure on acquiring such a building or structure, qualifies for an SBA. The following note has been updated for the changes announced
Employee benefit trusts (EBTs) are commonly used to support employees’ share schemes and to provide other benefits to employees in the form of pensions and bonuses.Their use has been significantly affected by the introduction of the disguised remuneration rules. Although the statutory exclusions
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