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UPDATE STATUS
ABOUT THE AUTHOR
FOREWORD
FORMS OF DOING BUSINESS
Main Forms of Doing Business with a Legal Presence
Main Forms of Doing Business
FORMATION
Main Formation Requirements
Public Limited Company
Private Limited Company
UK Establishments
CORPORATE RESIDENCE
Corporate Tax Residence
Practical Aspects of Tax Residence
Potential Exclusion from Treaty Benefits for Failure to Meet Residence Test
Deemed Acquisition of Tax Residence Status by Foreign Entities
Tax Consequences of Acquisition or Loss of Tax Residence
Specific (Deemed) Residence Rules for Partnerships, Hybrid and Specific Other Entities
PERMANENT ESTABLISHMENTS
Foreign PE of a Domestic Entity
Domestic PE of a Foreign Entity
PE Force of Attraction Principle
Branch Profit (Deemed) Remittance Tax
PE Risk Grid for Foreign Entities Involved in Business Activities
TAX BASE
Tax Base for Resident Entities
Treatment of Foreign Profits / Losses
Tax Consolidation / Group Treatment
Tax Base for Non-Resident Entities
Source Rules with Respect to Income Derived by Non-Residents
DETERMINATION OF TAXABLE INCOME
Main Rules Governing the Determination of Taxable Income
Main Differences between Commercial and Tax Accounting
Depreciation and Amortization
Reserves and Provisions
Deduction of Cross-Border Payments and Non-Deductible Expenses
Excluded and Segregated Income
Distributions from Controlled Companies
Distributions on Non-Redeemable Ordinary Shares
Distributions in Respect of Portfolio Holdings
Distributions Derived from Transactions not Designed to Reduce Tax
Distributions in Respect of Shares Accounted for as Liabilities
No Gain / No Loss Transfers
LOSSES
Ordinary losses
Property Losses
Terminal Losses
Losses from Abroad
Capital Losses
TAX RATES
Residents
Corporate Income Tax
Other Taxes
Special Tax Rates for Unit Trusts
Non-Residents
Corporate/Profit Taxes
Withholding Taxes
Exit Strategies
FOREIGN TAX CREDITS
INCENTIVES AND SPECIAL REGIMES
Holding Regimes
Intellectual Property Management Regimes
Incentives for R&D
Creative Industry Tax Reliefs
Enterprise Zones
Investment Zones
Tonnage Tax Regime
Energy Saving Products
BUSINESS TRANSFORMATION AND RE-ORGANIZATION
Direct and Indirect Tax Consequences of Re-Organizations
Mergers
Tax Consequence of Business Emigration, Corporate Inversions and the Cessation of Business
VAT ON INTERNATIONAL TRANSACTIONS
VAT on the Supply of Goods by Non-Residents
VAT on the Supply of Services by Non-Residents
Refund of VAT to Non-Residents
BASE PROTECTION AND ANTI-AVOIDANCE MEASURES
GAAR and General Anti-Avoidance Measures
Main General Anti-Avoidance Rule
Targeted Anti-Avoidance Rules (“TAAR”)
Thin-capitalization and other Restrictions to Interest Deduction
CFC and Similar Regimes
Profits attributable to UK Significant People Functions (“SPF”)
Non-trading Finance Profits
Trading Finance Profits
Captive Insurance Business
Solo Consolidation
Exemptions
Transfer Pricing
Main Rules
Specific TP Issues
Documentation Requirements
APAs and Dispute Resolution Mechanisms
Other Anti-Avoidance Rules
TAX MANAGEMENT AND COMPLIANCE
Books and Records
Type of Assessment
Calendar of Important Compliance Events
Tax Audits
Audit Process
Statute of Limitations
Interest and Penalties
Interest Compensation for Overpayment of Tax
Appeal Procedures
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