For UK corporation tax purposes an overseas company operating in the UK may have:
● a subsidiary;
● a branch (permanent establishment); or
● no taxable presence.
This will in turn determine the corporation tax liability. A UK resident subsidiary will be subject to corporation tax on its worldwide income whereas an overseas company with a permanent establishment in the UK will only be subject to corporation tax on the profits attributable to the permanent establishment.
If it can avoid a taxable presence altogether an overseas company will also avoid a UK corporation tax liability. However in some cases a legal entity will be preferable even where there would otherwise be no taxable...
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For UK corporation tax purposes an overseas company operating in the UK may have:
● a subsidiary;
● a branch (permanent establishment); or
● no taxable presence.
This will in turn determine the corporation tax liability. A UK resident subsidiary will be subject to corporation tax on its worldwide income whereas an overseas company with a permanent establishment in the UK will only be subject to corporation tax on the profits attributable to the permanent establishment.
If it can avoid a taxable presence altogether an overseas company will also avoid a UK corporation tax liability. However in some cases a legal entity will be preferable even where there would otherwise be no taxable...
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:
