Robert Langston summarises the basic rules and planning opportunities to maximise the benefit of double tax relief
UK resident companies are taxed on their worldwide income but they may also suffer tax in another jurisdiction – for example withholding tax on interest fees or royalties or tax on the profits of an overseas permanent establishment. This jurisdiction (as the source jurisdiction) usually has the primary taxing right as the income arises there and double tax relief must be obtained in the UK (the residence jurisdiction).
Double tax relief may be either be under the terms of a double tax agreement or unilateral relief where there is no agreement in place. The basic rules are outlined below. However there are a number of situations where full relief will not be available and this article outlines some ways in which transactions can be structured to mitigate...
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Robert Langston summarises the basic rules and planning opportunities to maximise the benefit of double tax relief
UK resident companies are taxed on their worldwide income but they may also suffer tax in another jurisdiction – for example withholding tax on interest fees or royalties or tax on the profits of an overseas permanent establishment. This jurisdiction (as the source jurisdiction) usually has the primary taxing right as the income arises there and double tax relief must be obtained in the UK (the residence jurisdiction).
Double tax relief may be either be under the terms of a double tax agreement or unilateral relief where there is no agreement in place. The basic rules are outlined below. However there are a number of situations where full relief will not be available and this article outlines some ways in which transactions can be structured to mitigate...
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:
