Overview of concepts

Produced by Tolley in association with Anne Fairpo
Overview of concepts

The following Corporation Tax guidance note Produced by Tolley in association with Anne Fairpo provides comprehensive and up to date tax information covering:

  • Overview of concepts
  • Common situations
  • Overseas company establishing in the UK
  • UK company establishing outside the UK
  • Holding companies
  • Financing
  • Intellectual property
  • Transfer pricing

Common situations

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.

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 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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