On 24 May, HMRC added a new chapter to its International Manual (INTM610000-INTM610300) concerning the profit fragmentation rules introduced from April 2019 by Finance Act 2019 Sch 4.
These rules target arrangements through which individuals carrying on a trade or profession, including members of a partnership, or UK-resident companies transfer a disproportionate part of their profits to offshore entities in low tax jurisdictions. The arrangements targeted by this legislation will typically involve:
Where the rules apply, HMRC will counteract the arrangement by attributing the correct amount of profits to the UK-taxable source. See bit.ly/2WIpMOz.
On 24 May, HMRC added a new chapter to its International Manual (INTM610000-INTM610300) concerning the profit fragmentation rules introduced from April 2019 by Finance Act 2019 Sch 4.
These rules target arrangements through which individuals carrying on a trade or profession, including members of a partnership, or UK-resident companies transfer a disproportionate part of their profits to offshore entities in low tax jurisdictions. The arrangements targeted by this legislation will typically involve:
Where the rules apply, HMRC will counteract the arrangement by attributing the correct amount of profits to the UK-taxable source. See bit.ly/2WIpMOz.