Graham J Airs Slaughter and May writes on the question of whether the United Kingdom's corporate exit charge is contrary to the EC Treaty
Taxation of Chargeable Gains Act 1992 s 185 provides that when a company ceases to be resident in the United Kingdom for UK tax purposes it is deemed to have disposed of certain of its assets (so that subject to what follows it pays tax on any gains inherent in those assets). The assets concerned are assets that will not be used by the company for the purposes of a trade carried on through a UK permanent establishment after it has ceased to be UK-resident. The reason for that is that a UK-resident company pays tax on gains realised on assets wherever they are...
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Graham J Airs Slaughter and May writes on the question of whether the United Kingdom's corporate exit charge is contrary to the EC Treaty
Taxation of Chargeable Gains Act 1992 s 185 provides that when a company ceases to be resident in the United Kingdom for UK tax purposes it is deemed to have disposed of certain of its assets (so that subject to what follows it pays tax on any gains inherent in those assets). The assets concerned are assets that will not be used by the company for the purposes of a trade carried on through a UK permanent establishment after it has ceased to be UK-resident. The reason for that is that a UK-resident company pays tax on gains realised on assets wherever they are...
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:
