The financial sector has long called for the alignment of the taxation of overseas subsidiaries and branches, and the introduction of the branch exemption in the current Finance Bill broadly achieves this objective. The exemption is by an election for all of a company’s overseas branches. The election is likely to be made by companies with consistently profitable branches in territories with low tax rates. There are a large number of detailed rules, of which the most relevant to the financial sector concern withholding tax and manufactured payments.
