Robert Langston considers the tax issues which arise when an overseas company undertakes activities in the UK
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...
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:
Robert Langston considers the tax issues which arise when an overseas company undertakes activities in the UK
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...
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:
