Overview of concepts

By Tolley in association with Robert Langston of Saffery Champness

The following Corporation Tax guidance note by Tolley in association with Robert Langston of Saffery Champness provides comprehensive and up to date tax information covering:

  • Overview of concepts
  • Common situations

Common situations

International tax is relevant to a number of different situations. This guidance note outlines the most common situations. Also see the Glossary for terms which are frequently encountered when advising on international tax matters.

Overseas company establishing in the UK

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 Overview of transfer pricing principles 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 guidance notes.

An overseas company which becomes UK tax resident (because it is managed and controlled in the UK) will also be subject to UK corporation tax. See the Inbound migration guidance note.

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