The incorporation of a UK branch of an overseas company, or the overseas branch of a UK company, can result in chargeable gains. Robert Langston reviews the practical tax issues that should be considered
As outlined in my practice guide ‘Overseas companies setting up in the UK’ (Tax Journal dated 22 March 2010) a company can undertake activities in the UK through either a branch or a subsidiary. A UK company faces a similar choice when undertaking activities outside the UK.
For new activities a branch can offer certain advantages over a subsidiary to a UK parent company including offsetting losses against other UK profits. Often there is also a practical consideration – a branch can be easier to establish than a subsidiary and easier to close down if the activities do not prove successful.
However in due course the parent company may decide...
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The incorporation of a UK branch of an overseas company, or the overseas branch of a UK company, can result in chargeable gains. Robert Langston reviews the practical tax issues that should be considered
As outlined in my practice guide ‘Overseas companies setting up in the UK’ (Tax Journal dated 22 March 2010) a company can undertake activities in the UK through either a branch or a subsidiary. A UK company faces a similar choice when undertaking activities outside the UK.
For new activities a branch can offer certain advantages over a subsidiary to a UK parent company including offsetting losses against other UK profits. Often there is also a practical consideration – a branch can be easier to establish than a subsidiary and easier to close down if the activities do not prove successful.
However in due course the parent company may decide...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: