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International Manual
Publication Date: 2022
Publisher: Bloomsbury Professional
Copyright: 2022 Crown
International Manual
International tax issues including the principles of double taxation relief and an introduction to double taxation agreements
Last Update: 3rd May 2022
Contents
- INTM100000: Introduction
- Close sectionINTM120000: Company residence
- INTM120010: Why is company residence important?
- INTM120020: What this guidance replaces
- INTM120030: Overview
- INTM120040: The incorporation rule
- INTM120050: The incorporation rule: commencement and transitional provisions
- INTM120060: The case law rule: central management and control
- INTM120070: Treaty non-resident' companies
- INTM120080: Treaty tie-breakers and self-assessment
- INTM120085: Standard treaty tie-breakers
- INTM120090: Certificates of UK residence for companies
- INTM120100: Residence under foreign law
- INTM120110: Non-UK incorporated companies - cessation of business or liquidation
- INTM120120: When to question residence
- INTM120130: When HMRC will not normally review residence: introduction
- INTM120140: When HMRC will not normally review residence: limitations
- INTM120150: When HMRC will not normally review residence: examples
- INTM120160: When HMRC will not normally review residence: other cases
- INTM120170: When HMRC will not normally review residence: individual directors
- INTM120180: How to review residence
- INTM120185: HMRC Response to COVID-19
- INTM120190: When to make a submission to BAI
- INTM120200: Statement of Practice SP1/90
- INTM120210: Guidance originally published in the International Tax Handbook
- Close sectionINTM150000: Principles of Double Taxation Relief and Introduction to Double Taxation Agreements
- Close sectionINTM151000: Double taxation: concept and principles
- Close sectionINTM152000: Double taxation agreements: introduction
- Close sectionINTM153000: Description of double taxation agreements
- INTM153010: Description of double taxation agreements: general
- INTM153020: Personal scope
- INTM153030: Taxes covered
- INTM153040: General definitions
- INTM153050: Residence
- INTM153060: Permanent establishment
- INTM153070: Income from immovable property
- INTM153080: Business profits
- INTM153090: Shipping/air transport
- INTM153100: Associated enterprises
- INTM153110: Dividends
- INTM153120: Interest
- INTM153130: Royalties
- INTM153140: Management and technical fees
- INTM153150: Capital gains
- INTM153160: Independent personal services
- INTM153170: Dependent personal services (employment)
- INTM153180: Directors' fees
- INTM153190: Artistes/entertainers/athletes
- INTM153200: Pensions
- INTM153210: Government service
- INTM153220: Students
- INTM153230: Teachers
- INTM153240: Other income
- INTM153250: Elimination of double taxation
- INTM153260: Non-discrimination
- INTM153270: Mutual agreement procedure
- INTM153280: Exchange of information
- INTM153290: Diplomats
- INTM153300: Dates of entry into force
- INTM153310: Termination
- INTM153320: Other articles - relief limitation
- INTM153330: Excluded persons
- INTM153340: Partnerships
- Close sectionINTM154000: Double taxation agreements: residence
- INTM156000: Exchange of information: contents
- Close sectionINTM157000: Double taxation relief: information and claims
- Close sectionINTM160000: Double Taxation Relief
- Close sectionINTM161000: UK residents with foreign income or gains - double taxation relief
- INTM161010: General
- INTM161020: Relief under double taxation agreement
- INTM161030: Unilateral relief
- INTM161040: Same income
- INTM161050: Deduction instead of credit
- INTM161060: Deduction instead of credit - FA 1994, Sch 20
- INTM161070: Withdrawal of credit claims
- INTM161080: Deduction for taxes
- INTM161085: Deduction for taxes (amount brought into account)
- INTM161090: Credit or deduction
- INTM161100: Basic principles
- INTM161110: The source rule
- INTM161120: Exceptions to the source rule
- INTM161130: The source rule - concessions
- INTM161140: Definitions - root income basis, statutory income basis
- INTM161150: Repayment, carry forward
- INTM161160: Root income' basis - legal position
- INTM161170: Root income' basis - practice
- INTM161180: Statutory income basis
- INTM161190: ICTA 1988, s 794
- INTM161200: ICTA 1988, s 794 - exceptions
- INTM161210: Limit to amount of tax credit relief
- INTM161220: Foreign tax
- INTM161230: Overseas branches
- INTM161240: Measure of income
- INTM161250: Minimum foreign tax
- INTM161260: Taxes covered
- INTM161270: Tax spared' credit
- INTM161280: Computation of UK measure - tax spared
- INTM161290: Referrals and reports to Business, Assets & International
- INTM161300: Unilateral relief
- INTM161310: Lists of qualifying taxes
- INTM161320: Corresponding adjustments and the alternative method
- Close sectionINTM162000: UK residents with foreign income or gains - certificates of residence
- INTM162010: Introduction and scope of guidance
- INTM162020: Information to be supplied with a request
- INTM162030: What HMRC will check - reason and date for which certification is required
- INTM162040: What HMRC will check - whether the customer is a resident of the UK
- INTM162050: Dual Resident Companies
- INTM162060: UK and overseas branches or permanent establishments
- INTM162070: What HMRC will check - whether there are any obvious reasons why the customer might not be entitled to treaty benefits
- INTM162080: Meaning of beneficial ownership
- INTM162090: Meaning of subject to tax
- INTM162100: For individuals and companies
- INTM162110: For partnerships
- INTM162120: For trusts
- INTM162122: UK registered pension schemes
- INTM162130: Certification required to be supported by an apostille
- INTM162140: Letter of confirmation
- INTM162150: Customised certificates of residence and side letters
- INTM162160: How a customer should make a request
- INTM162170: Escalation routes for HMRC staff in cases of difficulty
- INTM162180: CORs & COVID-19
- Close sectionINTM162500: UK residents with foreign income or gains - claims for double taxation relief against UK tax
- INTM162510: Where claims made
- INTM162520: Evidence - general
- INTM162530: Evidence - self-assessment
- INTM162540: Retention of original records
- INTM162550: Unit/investment trusts
- INTM162560: Time limits
- INTM162570: Extended time limits
- INTM162580: Adjustments to foreign tax
- INTM162590: Disputed claims
- INTM162600: Method of allowing relief
- INTM162610: Cases where further assessment may be required
- INTM162620: Rate of exchange to use
- Close sectionINTM163000: UK residents with foreign income or gains - income arising abroad
- INTM163010: What income is subject to double taxation
- INTM163020: Trade receipts
- INTM163030: Branch profits
- INTM163040: Branch profits - unrelieved tax
- INTM163050: Branch profits - arm's length principle
- INTM163060: Long term contracts
- INTM163070: Accrued income
- INTM163080: Interest
- INTM163090: Royalties
- INTM163110: Dividends
- INTM163130: Partnerships
- INTM163140: Employment - general
- INTM163150: Employment - double taxation
- INTM163170: Government remuneration
- INTM163180: Government pensions
- INTM163190: Definition of government remuneration
- INTM163200: Colonial service pensions
- INTM163210: Teachers
- INTM163220: Export credit
- Close sectionINTM164000: UK residents with foreign income or gains - dividends
- INTM164010: Foreign dividends - glossary
- INTM164020: Dividend articles in double taxation agreements
- INTM164030: EC Directive
- INTM164040: Portfolio shareholders
- INTM164050: Portfolio shareholders - exceptions
- INTM164060: Direct investors - underlying tax
- INTM164070: Tax deducted
- INTM164080: Split rate taxes
- INTM164090: Dividend stripping
- INTM164100: Underlying tax
- INTM164110: Underlying tax - rate boosting
- INTM164120: Underlying tax - computation of relevant profits
- INTM164130: Underlying tax - dividend resolutions
- INTM164140: Underlying tax - minimising foreign tax paid
- INTM164150: Underlying tax - groups taxed as single entity overseas
- INTM164151: Consolidated tax calculation - joiners and leavers
- INTM164155: Tax deductions for dividends
- INTM164156: Accounts deductions for dividends
- INTM164160: Underlying tax - reserves
- INTM164170: Underlying tax - pre-merger profits - dividends paid to the UK before 21 March 2000
- INTM164180: Underlying tax - pre-merger profits - dividends paid to the UK on or after 21 March 2000
- INTM164190: Underlying tax - imputation systems
- INTM164200: Underlying tax - insurance companies
- INTM164210: Dividends received by UK companies on or after 31 March 2001 - background and overview
- INTM164215: Shares treated as loan relationships
- INTM164220: Dividends received by UK companies on or after 31 March 2001 - the mixer cap
- INTM164230: Dividends received by UK companies on or after 31 March 2001 - the mixer cap - examples and responsibility
- INTM164235: Dividends received by UK companies on or after 2 December 2004 - the ADP mixer cap
- INTM164240: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - overview
- INTM164250: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - Case A
- INTM164260: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - Case B
- INTM164270: Dividends received by UK companies on or after 31 March 2001 - onshore pooling
- INTM164280: Dividends received by UK companies on or after 31 March 2001 - ADP dividends
- INTM164290: Dividends received by UK companies on or after 31 March 2001 - ADP dividends - example
- INTM164300: Dividends received by UK companies on or after 31 March 2001 - dividends barred from onshore pools
- INTM164310: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - order of carry back
- INTM164320: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - order of use
- INTM164330: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - group surrender
- INTM164340: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - group surrender - dual resident company
- INTM164350: Unilateral relief - direct tax
- INTM164360: Unilateral relief - underlying tax
- INTM164370: Unilateral relief - underlying tax - chains of companies
- INTM164380: Unilateral relief - banks
- INTM164390: Unilateral relief - insurance companies
- INTM164400: Determination of rates of foreign underlying tax - general
- INTM164410: Determination of rates of foreign underlying tax - old Agreements
- INTM164420: Determination of rates of foreign underlying tax - 10% control cases
- INTM164430: Determination of rates of foreign underlying tax - insurance companies
- INTM164440: Determination of rates of foreign underlying tax - procedure
- INTM164443: Determination of rates of foreign underlying tax - procedure - information requirements
- INTM164450: Determination of rates of foreign underlying tax - UTG and CTSA
- INTM164460: Determination of rates of foreign underlying tax - information provided by UTG
- INTM164470: Determination of rates of foreign underlying tax - Case V computations - dividends received on or after 31 March 2001
- INTM164480: Determination of rates of foreign underlying tax - Case V computations - dividends received on or after 31 March 2001 with withholding tax
- INTM164490: Determination of rates of foreign underlying tax - Case V - standard cases - example
- INTM164500: Determination of rates of foreign underlying tax - Case V - inclusive rates - examples
- INTM164510: Determination of rates of foreign underlying tax - Case V - company tax deducted - example
- INTM164515: Determination of rates of foreign underlying tax - Case V - tax spared - example
- INTM164520: Paying agents
- INTM164530: Paying agents - provisional credit
- INTM164540: Paying agents - examples
- Close sectionINTM165000: UK residents with foreign income or gains - income tax
- INTM165010: General
- INTM165020: Statutory provisions
- INTM165030: Computation - assessable amount
- INTM165040: Limit of credit
- INTM165050: Examples of calculation of credit for foreign tax
- INTM165060: Overlap profits
- INTM165070: Overlap periods - giving credit
- INTM165080: More than one foreign tax
- INTM165090: Continuing sources
- INTM165100: Cessations after 1998 - example 1
- INTM165110: 1996-97 assessed on actual basis
- INTM165120: Averaged profits
- INTM165150: Cases I/II example
- INTM165160: Cases IV/V example
- INTM165170: 1996-97 actual basis
- INTM165180: Trades, professions set up 1996-97 onwards
- INTM165190: Cessations after 1998 - example 2
- INTM165200: Losses - introduction
- INTM165210: Losses - relief under ICTA 1988, s 380
- INTM165220: Losses - relief under ICTA 1988, s 385
- INTM165230: Losses - relief under ICTA 1988, s 388
- INTM165240: Losses - examples
- Close sectionINTM166000: UK residents with foreign income or gains - trusts
- Close sectionINTM167000: UK residents with foreign income or gains - corporation tax
- INTM167010: General
- INTM167020: Statutory provisions
- INTM167030: Chargeable gains
- INTM167040: ICTA 1988, s 795
- INTM167050: Chargeable gains - credit for foreign tax
- INTM167060: Limit of credit
- INTM167070: Accounting periods of more than one year
- INTM167080: Accounting periods ending on or after 3 June 1986 and on or before 5 April 1999; accounting periods beginning on or after 6 April 1999
- INTM167090: Apportion deductions
- INTM167100: Accounting periods ending on or after 3 June 1986 and on or before 5 April 1999; accounting periods beginning on or after 6 April 1999 - charges
- INTM167110: Accounting periods ending on or after 3 June 1986 and on or before 5 April 1999; accounting periods beginning on or after 6 April 1999 - ACT
- INTM167120: Loan relationships
- INTM167130: Loan relationships
- INTM167140: Non-trading loan relationships - pooling of credits and debits
- INTM167150: Loan relationships - grossing up of income and expense relief
- INTM167160: Loan relationships - matching of income and relief
- INTM167170: Loan relationships - provisional relief
- INTM167180: Loan relationships - mark to market
- INTM167190: Loan relationships - conversion to sterling
- INTM167200: Loan relationships -interest reflected in market value
- INTM167210: Loan relationships - apportionment of DTR
- INTM167220: Loan relationships - automatic relief
- INTM167225: Loan relationships - Credits on non-trading loan relationships: limit on DTR
- INTM167226: Loan relationships - Credits on non-trading loan relationships: limit on DTR - examples
- INTM167230: Loan relationships - examples
- INTM167240: Loan relationships - examples
- INTM167250: Loan relationships - relief for foreign tax - identification of UK tax - example 1
- INTM167260: Loan relationships - relief for foreign tax - identification of UK tax -example 2
- INTM167270: Loan relationships - relief for foreign tax - identification of UK tax - example 3
- INTM167280: Loan relationships - relief for foreign tax - identification of UK tax - example 4
- INTM167290: Loan relationships - relief for foreign tax - identification of UK tax - example 5
- INTM167300: Loan relationships - relief for foreign tax - identification of UK tax - example 6
- INTM167310: Loan relationships - relief for foreign tax - identification of UK tax - example 7
- INTM167320: Loan relationships - relief for foreign tax - identification of UK tax - example 8
- INTM167330: Foreign branch
- INTM167340: Losses - ICTA 1988, s 393(1) and ICTA 1988, s 394
- INTM167350: ACT and charges - examples
- INTM167360: Dividends - withholding tax
- INTM167370: Dividends - underlying tax
- INTM167380: Dividends - extension of relief
- INTM167390: Dividends - extension of relief - UK subsidiaries
- INTM167400: Dividends - control - related companies
- INTM167410: Dividends - subsidiaries entitled to underlying relief
- INTM167420: Dividends - portfolio investors entitled to underlying relief - ESC C1
- INTM167430: Dividends - voting power reduced after 1 April 1972 - extension of unilateral relief
- INTM167440: Foreign life fund
- INTM167450: General insurance
- INTM167460: Controlled foreign companies - Bricom Holdings Ltd v CIR
- INTM167470: Intangible fixed assets
- INTM167475: Intangible fixed assets - Non-trading items - Limit on relief
- INTM167476: Intangible fixed assets - Non-trading items - Limit on relief - examples
- INTM167480: Intangible fixed assets - examples
- Close sectionINTM168000: Foreign tax paid on trade income - limitation on credit
- INTM168010: 2005 legislation
- INTM168015: Examples
- INTM168020: Specific transactions - income bearing assets
- INTM168022: Anti-avoidance - Trade income
- INTM168023: 2009 legislation
- INTM168025: Specific transactions - derivatives
- INTM168030: Specific transactions - deductions for foreign tax
- INTM168035: Methods of approximation
- INTM168040: Combined results
- INTM168045: Subsequent years
- INTM168050: Transitional rule
- INTM168055: Manufactured Overseas Dividends (MODs)
- INTM168060: Royalties
- INTM168062: Management/technical fees
- INTM168063: Artistes/athletes/sportsmen
- INTM168065: FA 2005, s 86 - Case V Income
- INTM168070: 1998 legislation
- INTM168075: 1998 legislation - detail
- INTM168080: 1998 legislation - Calculating the limit
- INTM168090: 1998 legislation - Loan interest
- INTM168100: 1998 legislation - First credit limit
- INTM168110: 1998 legislation - Foreign tax paid
- INTM168120: 1998 legislation - Spared tax
- INTM168130: 1998 legislation - Second credit limit
- INTM168140: 1998 legislation - Expenditure
- INTM168150: 1998 legislation - Expenditure not readily identifiable
- INTM168160: 1998 legislation - ‘Just and reasonable’ financing cost
- INTM168170: 1998 legislation - Apportioned financing cost
- INTM168180: 1998 legislation - Regulations - SI 1988/88
- INTM168190: 1998 legislation - Regulations - SI 1999/3330
- INTM168200: 1998 legislation - Underlying relief
- INTM168210: 1998 legislation - Examples
- INTM168220: 1987 legislation
- Close sectionINTM168300: Double taxation relief - foreign tax credit relief for non-residents trading in the UK
- Close sectionINTM169000: UK residents with foreign income or gains - capital gains tax
- INTM169010: Introduction
- INTM169020: Legislation
- INTM169030: Foreign taxes
- INTM169040: Gain taxed UK/abroad
- INTM169050: Not resident but “ordinarily resident”
- INTM169060: Resident shareholders in non-resident companies - TCGA 1992, s 13
- INTM169070: Credit claimed
- INTM169080: Remittance basis
- INTM169090: Deduction not credit
- INTM169100: Amount of foreign tax credit relief - general
- INTM169110: Amount of foreign tax credit relief - more than one gain
- INTM169120: Amount of foreign tax credit relief - losses
- INTM169130: Amount of foreign tax credit relief - exemption from tax
- INTM169140: Amount of foreign tax credit relief - extent to which a gain is doubly taxed
- INTM169150: Amount of foreign tax credit relief - basis of allowance
- Close sectionINTM170000: Anti-avoidance legislation
- INTM170010: Outline
- INTM170020: Scope
- INTM170030: Trigger conditions
- INTM170040: Circumstances which cause the legislation to take effect
- INTM170050: Effect of legislation
- INTM170060: Notices
- INTM170070: Procedure for notices
- INTM170080: Disputes
- INTM170090: Discovery Notices
- INTM170100: Penalties
- INTM170110: Clearances
- INTM170120: General Clearances
- INTM170130: Underlying tax
- INTM170140: Commencement
- Close sectionINTM180000: Foreign entity classification for UK tax purposes
- Close sectionINTM161000: UK residents with foreign income or gains - double taxation relief
- Close sectionINTM190000: Controlled Foreign Companies
- Close sectionINTM191000: Overview of CFC rules
- Close sectionINTM194000: Introduction to the CFC Charge
- Close sectionINTM197000: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply:
- Close sectionINTM200000: The CFC Charge Gateway Chapter 4 - Profits attributable to UK activities
- INTM200100: Introduction
- INTM200200: Terms used in Chapter 4
- INTM200300: Identification of SPFs
- INTM200400: Flowchart
- INTM200500: The Steps
- INTM200600: Exclusions - Economic value
- INTM200700: Exclusions - Independent companies' arrangements
- INTM200800: Exclusions - Trading profits
- INTM201000: Case Study
- Close sectionINTM203000: The CFC Charge Gateway Chapter 5 - Non-trading Finance Profits
- Close sectionINTM207000: The CFC Charge Gateway Chapter 6 - Trading Finance Profits
- Close sectionINTM210000: The CFC Charge Gateway Chapter 7 - Captive Insurance Business
- INTM210100: Introduction
- INTM210200: Interaction with Other Chapters
- INTM210300: Basic Rule
- INTM210400: Contracts of insurance falling within TIOPA 2010, s 371GA(2)
- INTM210500: Interaction with Transfer Pricing
- INTM210600: Exempt Foreign Permanent Establishments
- INTM210700: Contracts of Reinsurance - TIOPA 2010, s 371GA(5)
- INTM210800: Captive Insurance Companies resident in an EEA state
- Close sectionINTM213000: The CFC Charge Gateway Chapter 8 - Solo consolidation
- Close sectionINTM216000: Chapter 9 - Exemptions for profits from Qualifying Loan Relationships
- INTM216100: Overview
- INTM216400: Introduction
- INTM216600: Scope of the Rules
- INTM217000: What is a Qualifying Loan Relationship
- INTM217300: What is Excluded from the definition of a Qualifying Loan Relationship
- INTM218100: How do you determine the profits of a Qualifying Loan Relationship
- INTM218600: The 75% Exemption
- INTM218700: Full Exemption - Qualifying Resources
- INTM219100: Matched Interest Rule
- INTM219500: Transfer Pricing adjustments in the context of Chapter 9
- INTM219600: UK company used as a conduit in a CFC shelter
- INTM219700: Double Taxation Relief and UK companies used as a conduit
- INTM220000: Interaction of Chapter 9 Exemption with the Arbitrage Rules
- INTM220100: Exemptions for profits from Qualifying Loan Relationships: Claims
- Close sectionINTM224000: Entity Exemptions
- Close sectionINTM227000: Relevant Interests in a CFC
- Close sectionINTM230000: Creditable Tax of a CFC
- Close sectionINTM233000: Apportionment of a CFC's Chargeable Profits and Creditable Tax
- Close sectionINTM236000: Control
- Close sectionINTM239000: Assumed Taxable Total Profits, Assumed Total Profits and the Corporation Tax Assumptions
- INTM239100: Introduction
- INTM239200: Assumed Taxable Total Profits and Assumed Total Profits
- INTM239300: Corporation Tax Assumptions
- INTM239400: UK Residence
- INTM239500: Example
- INTM239600: Close Company
- INTM239700: Claims and Elections
- INTM239800: Claims and Elections - disapplication of assumption
- INTM239900: Elections under Section 9A of CTA 2010
- INTM240000: Elections for Leases to be treated as Long Funding Leases
- INTM240100: Intangible Fixed Assets
- INTM240200: Group Relief
- INTM240300: Capital Allowances
- INTM240400: Unremittable Overseas Income
- INTM240500: Tax advantages
- INTM240600: Disguised Interest
- INTM240700: Shares Accounted for as Liabilities
- INTM240800: Double Taxation Relief - Counteraction Notices
- Close sectionINTM242000: Residence of CFCs
- Close sectionINTM245000: Management and collection of a CFC charge and reliefs available against a CFC charge
- INTM245100: Introduction
- INTM245200: Application of the Taxes Acts to the CFC charge
- INTM245300: Just and reasonable apportionments
- INTM245400: Relief against a sum charged on a chargeable company
- INTM245500: Appeals affecting more than one person
- INTM245600: Recovery of sum charged from other UK resident companies
- Close sectionINTM248000: Definitions for terms in Part 9A
- Close sectionINTM251000: How the corporate tax regime works for CFCs
- INTM251100: CFC supplementary pages
- INTM251200: When to make a return in respect of a CFC
- INTM251300: How to complete the CFC supplementary pages
- INTM251400: CFC supplementary pages (forms CT600 & CT600B reproduced)
- INTM251500: HMRC Enquiries: records
- INTM251600: HMRC Enquiries: penalties
- INTM251700: Appeals
- INTM251800: Notice of liability
- INTM251900: Clearances: General
- INTM252000: Clearances: What to include in the application
- INTM252100: Clearances: Further information necessary for specific Chapters
- INTM252200: Clearances: Where to send applications
- Close sectionINTM254000: Guidance relating to superseded legislation
- Close sectionINTM260000: Non-residents trading in the UK
- INTM260500: PE definition - derivation and destination table
- Close sectionINTM261000: Introduction
- Close sectionINTM262000: Is there a charge under domestic legislation
- Close sectionINTM264000: permanent establishment: domestic and treaty law
- INTM264100: Domestic and treaty law: Introduction
- INTM264200: Domestic law and treaty law
- INTM264300: Domestic and treaty law: permanent establishment definition
- INTM264350: BEPS update to Article 5 of the OECD Model Tax Convention in Income and on Capital (‘MTC’)
- INTM264400: Domestic and treaty law: fixed place of business
- INTM264500: Dependent agent permanent establishment (‘DAPE’)
- INTM264600: Permanent establishment: domestic and treaty law: taxation of services
- INTM264700: Domestic and treaty law: Industry focus 1: e-commerce
- INTM264800: Domestic and treaty law: Industry focus 2: building site or construction or installation project
- Close sectionINTM267000: Profits of the PE
- INTM267010: Introduction to attribution
- INTM267020: Construction of the domestic charge to tax on non-residents
- INTM267030: Domestic provisions on quantifying chargeable profits - Income Tax and Corporation Tax
- INTM267040: The separate entity principle and use of transfer pricing methodology
- INTM267050: Attribution - method of calculation of chargeable profits
- INTM267060: Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Comparable Uncontrolled Price
- INTM267070: Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Resale Method
- INTM267080: Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Cost Plus
- INTM267090: Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Profit Split Method
- INTM267100: Allocation of expenses in the attribution exercise
- INTM267110: Interest receivable by PE
- INTM267120: Attribution of capital to the permanent establishment - companies only: FA2003 domestic legislation - an overview
- INTM267130: Attribution of capital to the permanent establishment - companies only: practical 4 step approach
- INTM267140: Attribution of capital to the permanent establishment - companies only: alternative approaches to calculating the capital attribution tax adjustment
- INTM267150: Attribution of capital to the permanent establishment - companies only: practical example - non-financial business
- INTM267160: Treaty provisions - Article 7 (business profits article) - interaction with domestic provisions
- INTM267170: PE capital gains chargeable on the non-resident
- INTM267180: Non-residents trading in the UK: overseas permanent establishments of UK resident companies: overview
- INTM267190: Non-residents trading in the UK: overseas permanent establishments of UK resident companies: the capital attribution approach
- INTM267200: Non-residents trading in the UK: overseas permanent establishments of UK resident companies: approach to capital attribution in the host state
- INTM267500: UK subsidiaries of foreign banks and foreign banks trading in the UK through permanent establishments
- Close sectionINTM268000: ‘Machinery’ provisions for assessment and collection via UK representatives
- INTM268010: Introduction: What are the machinery provisions for assessment and collection?
- INTM268020: Who can be the non-resident's UK representative?
- INTM268030: Extent of UK representative's liability
- INTM268040: What assessments should be raised and how is that done?
- INTM268050: What other obligations does the UK representative have?
- Close sectionINTM269000: Transactions carried out through UK investment managers, brokers or Lloyds agents
- INTM269010: Introduction
- INTM269020: Investment manager exemption: the legislation
- INTM269030: Investment manager exemption: effect on potential liabilities of UK representative
- INTM269035: Investment manager exemption: interaction with double taxation treaties and other domestic legislation
- INTM269040: Lloyd's members' agents
- INTM269050: Brokers
- INTM269060: Investment manager exemption: conditions
- INTM269065: Investment manager exemption: consequences of not meeting conditions
- INTM269070: Investment managers: the definition of “investment transaction”
- INTM269072: Investment managers - “investment transaction” - transactions in relevant contracts
- INTM269074: Investment managers - “investment transaction” - transactions resulting in a loan relationship or related transaction
- INTM269076: Investment managers - “investment transaction” - transactions in units in collective investment schemes
- INTM269080: Investment managers - the independence test - examples of when satisfied
- INTM269090: The independence test: meaning of “substantial part”
- INTM269100: The independence test: meaning of “widely held”
- INTM269105: Master/feeder funds
- INTM269110: Investment managers: the 20% rule
- INTM269120: The 20% rule: qualifying period of no more than 5 years - example
- INTM269130: The 20% rule: transparent and opaque funds
- INTM269140: The 20% rule calculation: an example - an opaque fund
- INTM269150: The 20% rule calculation: an example: a transparent collective investment scheme
- INTM269155: The 20% rule: consequences of not meeting the rule
- INTM269160: Interaction of the independence test and the 20% rule
- INTM269170: Customary rate of remuneration test
- INTM269175: Customary rate of remuneration test: avoidance
- INTM269180: Limit to Income Tax charge on non-residents
- INTM269190: Statement of Practice 1/01
- INTM269200: Statement of Practice 1/01 (as revised and reissued November 2016)
- INTM269500: Investment from abroad: Inward Investment Support
- Close sectionINTM280000: Foreign permanent establishments of UK companies
- Close sectionINTM281000: Foreign Permanent Establishments of UK Companies - introduction
- INTM281010: Foreign Permanent Establishments of UK Companies : Introduction: overview
- INTM281020: Foreign Permanent Establishments of UK Companies : Introduction: election for CTA 2009, s 18A to take effect
- INTM281030: Foreign Permanent Establishments of UK Companies : Introduction: procedures
- INTM281040: Foreign Permanent Establishments of UK Companies : Introduction: exempt profits or losses: definition
- INTM281050: Foreign Permanent Establishments of UK Companies : Introduction: exempt profits or losses: treaty attribution of profits to a PE
- INTM281060: Foreign Permanent Establishments of UK Companies : Introduction: exempt profits or losses: interaction between credit relief and PE exemption
- INTM281070: Foreign Permanent Establishments of UK Companies : Introduction: exempt profits or losses: treaties giving additional taxing rights to the PE state
- INTM281080: Foreign Permanent Establishments of UK Companies : Introduction: exempt profits or losses: calculation
- INTM281090: Foreign Permanent Establishments of UK Companies : Introduction: exempt profits or losses: profits attributable to PEs for purposes of TIOPA10
- Close sectionINTM282000: Foreign Permanent Establishments of UK Companies - chargeable gains
- INTM282010: Chargeable gains: introduction
- INTM282020: Chargeable gains: immovable property
- INTM282030: Chargeable gains: attribution of assets and gains
- INTM282040: Chargeable gains: determining exempt gains and losses
- INTM282050: Chargeable gains: foreign gains or loss in earlier period
- INTM282060: Chargeable gains: no gain, no loss transfers
- INTM282070: Chargeable gains: exclusion of gains of close companies
- INTM282080: Chargeable gains: relief for replacement of business assets
- Close sectionINTM283000: Foreign Permanent Establishments of UK Companies - intangible fixed assets
- Close sectionINTM284000: Foreign Permanent Establishments of UK Companies : contents transition to exemption provisions
- INTM284010: Transition to exemption provisions: introduction
- INTM284020: Transition to exemption provisions: transitional rule: opening negative amount
- INTM284030: Transition to exemption provisions: transitional rule: matching
- INTM284040: Transition to exemption provisions: streaming of permanent establishment losses
- INTM284050: Transition to exemption provisions: transfers of permanent establishment business
- Close sectionINTM285000: Foreign Permanent Establishments of UK Companies - capital allowances
- INTM285010: Capital allowances: plant & machinery: introduction
- INTM285020: Capital allowances: plant & machinery: notional Cas
- INTM285030: Capital allowances: plant & machinery: transition to exemption
- INTM285040: Capital allowances: plant & machinery: pools of expenditure
- INTM285050: Capital allowances: plant & machinery: leasing
- INTM285060: Capital allowances: mineral extraction allowances and other allowances
- Close sectionINTM286000: Foreign Permanent Establishments of UK Companies - anti diversion rule
- INTM286010: Anti-diversion rule: introduction for relevant periods beginning before 1 January 2013
- INTM286020: Anti-diversion rule: lower level of tax test
- INTM286030: Anti-diversion rule: motive test
- INTM286040: Anti-diversion rule: motive test: condition A
- INTM286050: Anti-diversion rule: motive test: condition B
- INTM286060: Anti-diversion rule: proportionate reduction where motive test not met
- INTM286070: Anti-diversion rule: transitional provisions
- INTM286080: Anti-diversion rule: safe harbour provisions
- INTM286090: Anti-diversion rule: cases where safe harbour provisions not met
- INTM286100: Anti-diversion rule: “Period of Grace” clearances
- INTM286110: Anti-diversion rule: proportionate reduction where tainted relevant transactions arise
- INTM286300: Anti-diversion rule: Introduction for relevant accounting periods beginning on or after 1 January 2013
- INTM286310: Anti-diversion rule: When does it apply?
- INTM286320: Anti-diversion rule: Diverted Profits Gateway Approach
- INTM286330: Anti-diversion rule: Application of the Diverted Profits Gateway
- INTM286340: Anti-diversion rule: Initial gateway filter - Chapter 3
- INTM286350: Anti-diversion rule: Initial gateway filter - Does Chapter 4 apply?
- INTM286360: Anti-diversion rule: Initial gateway filter - Does Chapter 5 apply?
- INTM286370: Anti-diversion rule: Initial gateway filter - Does Chapter 6 apply?
- INTM286380: Anti-diversion rule: Initial gateway filter - Does Chapter 7 apply?
- INTM286390: Anti-diversion rule: Chapter 4
- INTM286400: Anti-diversion rule: Chapters 5 and 9
- INTM286410: Anti-diversion rule: Chapter 6
- INTM286420: Anti-diversion rule: Chapter 7
- INTM286430: Anti-diversion rule: Diverted profits gateway approach - Example 1
- INTM286440: Anti-diversion rule: Diverted profits gateway approach - Example 2
- INTM286450: Anti-diversion rule: Diverted profits gateway approach - Example 3
- INTM286460: Anti-diversion rule: Entity Exemption Approach
- INTM286470: Anti-diversion rule: Application of the Entity Exemption Approach
- INTM286480: Anti-diversion rule: Chapter 11 - Excluded Territories Exemption
- INTM286490: Anti-diversion rule: Chapter 12 - Low Profits Exemption
- INTM286500: Anti-diversion rule: Chapter 13 - Low Profit Margin Exemption
- INTM286510: Anti-diversion rule: Chapter 14 - Tax Exemption
- Close sectionINTM287000: Foreign Permanent Establishments of UK Companies - exclusions and definitions
- INTM287010: Exclusions: particular circumstances
- INTM287020: Exclusions: operation of restriction on “payments subject to deduction”
- INTM287030: Exclusions: restriction on exemption
- INTM287040: Exclusions: position of payer
- INTM287050: Exclusions: banks and interest on advances from banks
- INTM287060: Definitions
- INTM287070: Exclusions: Investment Business
- Close sectionINTM288000: Profits attributable to a permanent establishment of a UK resident company - TIOPA 2010, s 43
- INTM288010: Profits attributable to a permanent establishment of a UK resident company - TIOPA 2010, s 43: overview
- INTM288020: Profits attributable to a permanent establishment of a UK resident company - TIOPA 2010, s 43: the capital allocation approach
- INTM288030: Profits attributable to a permanent establishment of a UK resident company - TIOPA 2010, s 43: special considerations for Pes of insurance companies
- INTM288040: Profits attributable to a permanent establishment of a UK resident company - TIOPA 2010, s 43: approach to capital attribution in the host state
- INTM288050: Profits attributable to a permanent establishment of a UK resident company - TIOPA 2010, s 43: allotted free capital outside the arm's length range
- Close sectionINTM281000: Foreign Permanent Establishments of UK Companies - introduction
- Close sectionINTM330000: DT applications and claims in CAR Residency
- Close sectionINTM330010: Introduction
- Close sectionINTM330100: Overview of dual purpose forms
- Close sectionINTM330300: Signature of declarations
- INTM330310: Who should sign the declaration - individuals
- INTM330320: Declarations signed by an attorney on behalf of an individual
- INTM330330: Who should sign the declaration - minors
- INTM330340: Who should sign the declaration - deceased persons
- INTM330350: Who should sign the declaration - companies
- Close sectionINTM330500: Certification by overseas tax authorities
- Close sectionINTM330700: Time limit
- INTM330710: Introduction to time limit
- INTM330720: Time limit for making claims
- INTM330730: Table showing time limit for making claims
- INTM330740: Claim signed in time but received after expiry of time limit
- INTM330750: Notice of intention to claim
- INTM330760: Exceptions to the normal time limit
- INTM330770: Attempt to claim after expiry of time limit
- INTM330780: Applications for relief at source
- INTM330790: Questions about an extension to the time limit
- INTM330800: Challenges to application of time limit
- INTM330810: Time limit in other countries
- INTM330820: Claim in connection with tax paid following a late assessment
- INTM330830: Time limit for making assessments
- Close sectionINTM331000: Self Assessment - Repayment claims from non-residents
- INTM331010: A basic guide to Self Assessment and how TMA 1970, Sch 1A applies to claims made by non-residents
- INTM331050: Procedural guide - how to check that you have a valid claim
- INTM331100: Procedural guide - how to correct a claim (no enquiry)
- INTM331150: Procedural guide - how you give effect to claims and amendments (no enquiry)
- INTM331200: Procedural guide - how to open an enquiry into a claim
- INTM331250: Procedural guide - conduct of an enquiry
- INTM331300: Procedural guide - how to close an enquiry
- INTM331350: Procedural guide - how you give effect to amendments following an enquiry
- INTM331400: Procedural guide - what to do if you receive an appeal against an amendment to a claim
- Close sectionINTM332000: Beneficial ownership
- INTM332010: What beneficial ownership is
- INTM332020: Why beneficial ownership matters
- INTM332030: How you decide if the beneficial ownership condition is satisfied
- INTM332040: Indofood: the Judgement
- INTM332050: HM Revenue & Customs reaction to Indofood case
- INTM332060: Indofood: Impact on particular cases
- INTM332070: Indofood: Existing and new cases
- INTM332080: Indofood: Examples of application
- Close sectionINTM332200: Subjection to tax in the DT country
- Close sectionINTM332400: Remittance
- Close sectionINTM332600: Permanent establishment and special relationship
- INTM332610: What a permanent establishment is
- INTM332620: When you have to consider PE
- INTM332630: What the PE provisions are
- INTM332640: How you know the PE condition is satisfied
- INTM332650: Claimant with an associate outside the UK with a PE in the UK
- INTM332660: Claimant which is a subsidiary of a UK company
- INTM332670: What Special Relationship is
- INTM332680: How you recognise the ‘Special Relationship’ condition
- INTM332690: How you know the special relationship condition is satisfied
- Close sectionINTM333000: Vouchers
- INTM333010: What a voucher is
- INTM333020: How vouchers are issued
- INTM333030: Common types of vouchers
- INTM333040: Details on vouchers
- INTM333050: Signing of vouchers
- INTM333060: Declaration of ownership on vouchers
- INTM333070: Names on vouchers
- INTM333080: When you can accept the name on the voucher
- INTM333090: When you should enquire about names on vouchers
- INTM333100: What to do with missing/duplicate/photocopy vouchers
- INTM333110: What a duplicate voucher looks like
- INTM333120: What a photocopy voucher looks like
- INTM333140: Double Taxation applications and claims: Vouchers: Intermediaries' own versions of vouchers
- INTM333150: Informal vouchers
- INTM333161: Vouchers showing Stock Dividends
- INTM333170: What a block holding is
- INTM333180: What a block voucher is
- INTM333210: Claims which include block items
- INTM333220: Block vouchers issued by Irish banks
- INTM333230: Verification of vouchers
- INTM333240: When vouchers should be verified
- INTM333260: Vouchers showing foreign tax
- INTM333270: What to do if the claimant has difficulty in providing vouchers
- INTM333290: What to do if the claimant wants vouchers returned
- INTM333300: What to do if you are not paying all the tax on a voucher
- INTM333310: What to do if you suspect a voucher has been altered
- INTM333320: What to do if you receive a subsidiary voucher for a single customer holding
- Close sectionINTM333500: Repayment interest
- INTM333510: What is repayment interest
- INTM333520: Who is entitled to repayment interest
- INTM333530: Member states of the European Economic Area - (EEA) and associated territories
- INTM333540: Countries and territories where companies do not qualify for repayment interest
- INTM333550: What information is required to calculate repayment interest
- INTM333560: How repayment interest is calculated for a 12 month accounting period
- INTM333570: How repayment interest is calculated for an accounting period that exceeds 12 months
- INTM333580: Correspondence about entitlement to repayment interest
- INTM333590: Company in liquidation
- Close sectionINTM333600: Repayment supplement
- Close sectionINTM333700: Arrears of tax
- Close sectionINTM333800: Refusal of relief
- Close sectionINTM333900: Exchange of Information and correspondence with overseas tax authorities
- INTM333910: Exchange of information provisions in Double Taxation Agreements
- INTM333920: Routine exchange of information material
- INTM333930: Forms 99FD
- INTM333940: Writing to the overseas tax authorities
- INTM333950: What to include in a letter to the overseas tax authorities
- INTM333960: If the overseas tax authorities dispute a decision
- INTM333970: Requests for information from overseas tax authorities
- Close sectionINTM334000: Relief at source over-allowed
- Close sectionINTM334500: Applicants/claimants - individuals
- INTM334510: Introduction
- INTM334520: Residence and ordinary residence
- INTM334530: Guidance on the rules of residence of individuals in the UK
- INTM334540: The definition of residence of individuals in a DTA
- INTM334550: How you know whether an individual is resident in the other country for the purposes of the DTA
- INTM334560: Individuals who are ‘double resident’
- INTM334570: The double residence ‘tests’ in DTAs and what to do if you have a case of double residence
- INTM334580: Individuals entitled to UK personal allowances
- Close sectionINTM335000: Companies
- INTM335010: How to tell that a claim is from a company
- INTM335020: Abbreviations used for companies in other countries
- INTM335030: What a limited company is
- INTM335040: Types of company claim
- INTM335050: First claims on form A1 (FOTRAs and foreign dividends) from companies
- INTM335060: The residence position of companies submitting DT claims
- INTM335070: What you do on receipt of a completed questionnaire 2300Q
- INTM335080: Companies resident in Antigua, Barbados, Cyprus and Jamaica
- INTM335090: Claims by liquidators
- Close sectionINTM335500: Applicants/claimants - Partnerships
- Close sectionINTM336000: Applicants/claimants - Pension funds
- Close sectionINTM336700: Applicants/claimants - International associations
- INTM336710: What an international association is
- INTM336720: What the difference is between an international association and an international organisation
- INTM336730: Residence status of an international association
- INTM336740: What relief international associations can claim from CAR Residency
- INTM336750: How you deal with claims and applications by international associations
- Close sectionINTM336900: Foundations, establishments and associations
- Close sectionINTM337100: Charities
- Close sectionINTM337300: Applicants/claimants - claims by financial concerns under Business Profits Article
- Close sectionINTM337500: Applicants/claimants - Construction Industry Scheme
- Close sectionINTM338000: Applicants/claimants - Overseas Collecting Societies
- INTM338010: What is an Overseas Collecting Society
- INTM338020: What is the Block Exemption Scheme
- INTM338030: Undertakings required by the Overseas Collecting Society
- INTM338040: Undertaking required by the UK Collecting Society
- INTM338050: Performing Right Society
- INTM338060: Mechanical Copyright Protection Society
- INTM338080: Authors Licensing Collecting Society
- INTM338090: Public Lending Right
- INTM338100: Design & Artists Copyright Society
- Close sectionINTM338500: Applicants/claimants - Provisional Treaty Relief Scheme
- INTM338510: Background
- INTM338520: Background continued
- INTM338530: One to One Loans
- INTM338540: One to One Loans: Application procedures
- INTM338550: Syndicated Loans
- INTM338560: Syndicated Loans continued
- INTM338570: Syndicated Loans: Application procedures
- INTM338580: Syndicated Loans: Application procedures continued
- INTM338590: Syndicated Loans: Application procedures continued
- INTM338600: Reviews of Syndicates
- INTM338610: Reviews of Syndicate Managers
- INTM338620: Additional information
- Close sectionINTM339500: Applicants/claimants - Trusts
- Close sectionINTM340000: Applicants/claimants - Estates and deceased persons
- INTM340010: Introduction
- INTM340020: Definitions
- INTM340030: Claims by personal representatives
- INTM340040: Pre-death income
- INTM340050: Claims by personal representatives on administration period income
- INTM340060: How to make an SA enquiry to establish a personal representative's entitlement to claim
- INTM340070: Income arising after the date of ascertainment of the residue
- INTM340080: Residence of personal representatives
- INTM340090: What happens if personal representatives of the deceased are resident in more than one country
- INTM340100: Attorney administrators
- INTM340110: What happens if a personal representative dies
- INTM340120: What happens if there is no Grant of Probate
- INTM340130: What happens if a life tenant of a will trust dies
- INTM340140: Laws of intestacy
- INTM340150: General enquiries about estates
- Close sectionINTM340500: Collective Investment Vehicles
- INTM340510: What a Collective Investment Vehicle is
- INTM340520: Claims by Collective Investment Vehicles - funds or trusts
- INTM340530: Claims by investment vehicles in corporate form
- INTM340540: How to deal with a claim by a Collective Investment Vehicle
- INTM340550: List of terms used to describe Collective Investment Vehicles
- Close sectionINTM342000: Types of income - Interest
- INTM342010: Background
- INTM342020: Interest rates linked to profits
- INTM342030: UK source
- INTM342040: Anti-bondwashing provisions
- INTM342050: Free of tax
- INTM342070: Loan Stock quoted on a stock exchange
- INTM342080: Privately Arranged Loans : Inter-company loans
- INTM342090: Privately Arranged Loans : Syndicated loans
- INTM342100: Privately arranged Loans : Non-company lenders
- INTM342110: UK Government securities
- INTM342120: Local Authority loan stocks
- INTM342130: Bank and Building Society interest
- INTM342140: Permanent Interest Bearing Shares
- INTM342150: Reinsurance Deposits
- INTM342160: Eurobonds
- INTM342170: Loose or Back Coupons
- INTM342180: National Savings and Investments
- INTM342190: Lloyds Premium Trust Fund
- INTM342200: Solicitors Client Accounts
- Close sectionINTM342500: Types of income - Royalties
- INTM342510: Background
- INTM342520: Copyright royalties
- INTM342530: Copyright royalties continued
- INTM342540: Copyright royalties continued
- INTM342550: Copyright royalties - beneficial ownership
- INTM342560: Copyright royalties - beneficial ownership continued
- INTM342570: Theatrical Plays
- INTM342580: Theatre Backers - Angels
- INTM342590: Professional Authors
- INTM342600: Copyright Protection Societies
- INTM342610: Public Lending Right
- INTM342620: Registered Designs
- INTM342630: Computer software
- INTM342640: Patent royalties
- INTM342650: Patent royalties continued
- INTM342660: Patent royalties continued
- Close sectionINTM343000: Types of income - Pensions and Annuities
- INTM343010: Background
- INTM343020: Government pensions
- INTM343030: Government pensions continued
- INTM343040: Government or Non-Government - list of pensions
- INTM343050: Supplementary Pension for Overseas Service
- INTM343060: Hong Kong Sterling Safeguard pensions
- INTM343070: War Widows pensions
- INTM343080: Wounds and Disability pensions
- INTM343090: Victoria Cross and other awards for valour
- INTM343100: Widows of Armed Forces Personnel
- INTM343110: Pensions for service outside the UK
- INTM343120: Merchant Navy pensions
- INTM343130: Employment (Non-Government) pensions
- INTM343140: Annuities
- INTM343150: Partnership Annuities
- INTM343160: Personal Pensions
- INTM343170: Annuity Purchase Deferral - draw down payments
- INTM343180: Permanent Health Insurance payments
- INTM343190: Social Security payments
- Close sectionINTM343500: Types of income - Dividends
- Close sectionINTM344000: Types of income - Distributions
- Close sectionINTM344500: Types of income - Other income
- Close sectionINTM345000: Manufactured payments
- Close sectionINTM345400: Overview of Double Taxation Agreements
- INTM345410: How double taxation arises
- INTM345420: What a Double Taxation Agreement is
- INTM345430: What is the statutory authority for drawing up DTAs & implementing them
- INTM345440: Terminology of DTAs
- INTM345450: Content of the DTAs
- INTM345460: What relief a DTA allows
- INTM345470: What types of ‘DT income’ the Centre for Non-Residents is concerned with
- INTM345480: Credit relief to overseas residents for UK tax
- INTM345490: Relief available to UK residents from the other country's tax
- INTM345500: What to do if you are asked a question about taxation in another country
- INTM345510: What to do if you receive a complaint about the other country's tax authorities
- Close sectionINTM367000: EU Directive - Interest & Royalties paid between associated companies - claims and applications by non-residents
- INTM367005: Claim forms
- INTM367010: Background
- INTM367015: Further background
- INTM367020: Examination procedures
- INTM367025: Member Countries of the European Union
- INTM367030: Business concerns that qualify to claim exemption
- INTM367035: List of ‘equivalent taxes’ in other Member States
- INTM367040: UK legislation - Sections 97 to 106 Finance Act 2004
- INTM367045: Statutory Instrument 2004 No 2622
- Close sectionINTM367500: Income from Estates
- INTM367510: Claims by beneficiaries of a UK estate
- INTM367520: How to give relief under an Other Income article
- INTM367530: Countries where relief is available under the Other Income article on distributions made by UK estates
- INTM367540: How to give relief by ‘looking through’
- INTM367550: Claims by beneficiaries of foreign estates
- INTM367560: Statutory time limit for claims by beneficiaries
- Close sectionINTM367600: Non-resident beneficiaries of non-resident trusts
- INTM367610: What to do if you receive a claim or application from a beneficiary of a non-resident trust
- INTM367620: Claims by non-resident beneficiaries of non-resident non-discretionary trusts
- INTM367630: Claims by non-resident beneficiaries of non-resident discretionary trusts
- INTM367640: What happens if the settlor of a discretionary trust is not excluded from benefit under the trust
- Close sectionINTM367700: Non-resident beneficiaries of UK trusts
- INTM367710: Introduction and definitions
- INTM367720: Claims and applications by non-resident beneficiaries of UK trusts
- INTM367730: Distributions to an absolute beneficiary or to a life tenant
- INTM367740: Distributions to an absolute beneficiary or to a life tenant - processing the claim
- INTM367750: Distributions to an absolute beneficiary or to a life tenant - claim supported by tax certificates in the name of trustees
- INTM367760: Distributions to an absolute beneficiary or to a life tenant - applications by beneficiaries to relief at source
- INTM367770: Distributions to an annuitant
- INTM367780: Distributions to a beneficiary with a discretionary or a contingent interest
- INTM367790: What methods of relief are available on discretionary payments from UK resident trustees
- INTM367800: Countries where relief is available under the ‘other income’ article on discretionary payments made by UK resident trustees
- INTM367810: Relief on discretionary payments made by UK resident trustees where no relief is available under an ‘other income’ article
- INTM367820: Extra Statutory Concession B18 (ESC/B18)
- INTM367830: ESC/B18 and dividends taxed at the ‘dividend trust rate’ (Schedule F trust rate)
- INTM367840: ESC/B18 and trustees' tax returns
- INTM367850: ESC/B18 and Self Assessment
- INTM367860: Dealing with claims by non-resident beneficiaries of UK discretionary trusts under ESC/B18
- INTM367870: Calculating relief due under ESC/B18
- INTM367880: How to manually calculate relief due under ESC/B18
- INTM367890: Example of manual calculation under ESC/B18
- INTM367900: Notes on types of underlying income in a discretionary trust
- INTM367910: What happens if the total net distributed in a year exceeds the total net available for distribution (‘overdistribution’)
- INTM367920: Trust Management Expenses
- INTM367930: Confidentiality when advising a beneficiary or agent about a payment
- INTM367940: Potential difficulties with claims under ESC/B18
- INTM367950: What to do if a trust return includes income not taxed at the Rate Applicable to Trusts
- INTM367960: Personal Allowances, tax bands and relief under ESC/B18
- Close sectionINTM368000: FOTRA securities
- INTM368010: What are FOTRA securities and how to identify them
- INTM368030: Background - the position from 6 April 1998
- INTM368040: The FOTRA condition
- INTM368050: FOTRA claim forms
- INTM368060: Exchange of information - form 99/FD
- INTM368070: Who will make FOTRA claims
- INTM368080: FOTRA and trusts - claims by beneficiaries
- INTM368090: FOTRA and trusts - claims by trustees
- INTM368100: FOTRA and estates
- INTM368110: FOTRA and DT claims
- INTM368120: Accrued income scheme
- Close sectionINTM368250: Foreign dividends and interest payments
- INTM368260: Background
- INTM368270: Payments of foreign dividends and interest - up to 31 March 2001
- INTM368280: Payments of foreign dividends and interest - from 1 April 2001
- INTM368290: What claims you may see
- INTM368300: Additional foreign withholding tax
- INTM368310: Exchange of information - form 99/FD
- INTM368320: Who will make claims
- INTM368330: Foreign dividends and interest payments: trusts - claims by beneficiaries
- INTM368340: Foreign dividends and interest payments: trusts - claims by trustees
- INTM368350: Foreign dividends and interest payments - estates
- INTM368500: Crown Immunity, Sovereign Immunity and Diplomatic Privilege
- Close sectionINTM370000: The Non-resident Landlords Scheme
- INTM370010: Overview of the Scheme
- INTM370020: Letting agents
- INTM370030: Tenants
- INTM370040: Compliance
- INTM370050: Non-resident landlords
- INTM370060: Usual place of abode
- INTM370070: How non-resident landlords can apply to get their UK rent paid gross
- INTM370080: What happens when HMRC approval is given?
- INTM370090: Appeals against non-approval
- Close sectionINTM400000: Interest and Royalty Payments: contents
- INTM400010: Overview
- INTM400020: Legislation
- INTM400030: What the Legislation says
- INTM400040: Who is affected by the Legislation?
- INTM400050: What an interest payment exemption notice covers
- INTM400060: Procedures for claims on interest payments
- INTM400070: Corporation Tax caseworker communication
- INTM400080: Handling enquiries into claims on interest payments
- INTM400090: Treatment of interst & royalties under the Legislatio
- INTM400100: What happens if a claim is refused or an exemption notice cancelled
- INTM400110: Anti-avoidance measures
- Close sectionINTM410000: Transfer pricing: legislation and principles
- Close sectionINTM410500: What is transfer pricing?
- Close sectionINTM412000: Transfer pricing - legislation - rules
- INTM412010: Introduction
- INTM412020: The basic transfer pricing rule
- INTM412030: Meaning of person
- INTM412040: The arm's length principle
- INTM412050: Meaning of ‘provision’ and ‘transaction’
- INTM412060: Participation in the management, control or capital of a person
- INTM412070: Exemptions: small and medium sized enterprises
- INTM412080: Exemptions: SME definition
- INTM412090: Exemptions: SMEs: list of countries
- INTM412100: SMEs: associated entities
- INTM412110: Exemptions: pre existing dormant companies
- INTM412120: Exemptions: Special cases
- INTM412130: Compensating adjustments
- INTM412140: Balancing payments
- Close sectionINTM413000: Transfer pricing - the main thin capitalisation legislation
- INTM413010: Overview
- INTM413020: Thin capitalisation legislation: Introduction
- INTM413030: The “would” and “could” arguments
- INTM413040: Summary of sections specific to thin capitalisation
- INTM413050: Potential UK tax advantage
- INTM413060: Transaction / series of transactions
- INTM413070: Separate entity basis for determining borrowing capacity
- INTM413080: The borrowing unit
- INTM413090: UK-UK thin capitalisation
- INTM413100: Special rules for lending between companies
- INTM413110: Guarantees - what they do and what they are
- INTM413120: Disregarding guarantees in working out the arm's length cost of debt
- INTM413130: Establishing the arm's length value of a guarantee
- INTM413140: Compensating adjustments for lenders
- INTM413150: Removal of disallowed interest from obligation to deduct tax
- INTM413160: Claims to compensating adjustments for guarantors
- INTM413170: Interaction between claims by lenders and guarantors
- INTM413180: The acting together rules
- INTM413190: Treatment of interest when it is paid
- INTM413200: Interest which exceeds the arm's length amount
- INTM413210: Payments of yearly interest made overseas
- INTM413220: Consequences of failing to deduct withholding tax
- INTM413230: The interaction between UK taxing rights and double taxation agreements
- INTM413240: Evolution of thin capitalisation legislation: pre 29 November 1994
- INTM413250: Evolution of the thin capitalisation legislation: 29 November 1994 - 31 March 2004
- INTM413260: Evolution of the thin capitalisation legislation: interest re-characterised as a distribution
- Close sectionINTM420000: Transfer pricing - methodology
- Close sectionINTM421000: OECD Guidelines
- INTM421005: Importance of Article 9 of OECD Guidelines
- INTM421010: Overview
- INTM421020: Comparability
- INTM421030: Comparable Uncontrolled Price
- INTM421040: Comparable Uncontrolled Price: the search for comparables
- INTM421041: Comparable uncontrolled price: Commodity Transactions
- INTM421050: Resale minus
- INTM421060: Cost plus
- INTM421070: Profit split
- INTM421080: Transactional net margin method
- INTM421090: Cost contribution arrangements
- INTM421100: Which transactions to review
- INTM421110: Intangibles
- Close sectionINTM422000: Advance Pricing Agreements
- INTM422010: Introduction
- INTM422020: What is an Advance Pricing Agreement?
- INTM422030: Types of agreement
- INTM422040: Who may apply?
- INTM422050: Expression of interest
- INTM422060: Term of agreement
- INTM422070: Formal application
- INTM422080: Evaluation
- INTM422090: Reaching agreement
- INTM422100: Monitoring and review
- INTM422110: Revocation and penalties
- INTM422120: Revising and renewing
- INTM422130: Information to include in the formal application
- INTM422140: sample agreement
- Close sectionINTM423000: Mutual Agreement Procedure
- INTM423010: Introduction to MAP
- INTM423020: Eligibility for MAP
- INTM423030: Access to MAP
- INTM423040: The MAP process
- INTM423050: The MAP process continued
- INTM423060: Concluding the MAP
- INTM423070: Methods of giving relief
- INTM423080: Arbitration
- INTM423090: Other matters
- INTM423100: Advice on responding to MAP requests
- INTM423110: HMRC contacts
- INTM423120: Links to other relevant documents
- INTM423130: Information requirements
- Close sectionINTM421000: OECD Guidelines
- Close sectionINTM440000: Transfer pricing - Types of transactions
- INTM440010: Overview
- INTM440020: Tangible goods
- INTM440030: Transfer of trading stock
- INTM440040: Land and buildings
- INTM440050: Leasing
- INTM440060: Services: introduction
- INTM440070: Services: arm's length price
- INTM440071: Services: Low Value-Adding Services
- INTM440080: Services: particular types
- INTM440090: Centrally provided services
- INTM440100: Particular elements of a transaction
- INTM440110: Intangibles: what are intangibles?
- INTM440120: Intangibles: how are intangibles exploited?
- INTM440130: Intangibles: fragmentation
- INTM440140: Intangibles: establishing an arm's length price for valuable intangible property
- INTM440150: Intangibles: branded goods
- INTM440160: Intangibles: product line income statements
- INTM440170: Intangibles: profit split method
- INTM440175: Establising an arm's length price for valuable intangibles: Uncertainty in valuation
- INTM440176: Establising an arm's length price for valuable intangibles: Hard to Value Intangibles
- INTM440180: Intangibles: royalties
- INTM440190: Series of transactions
- INTM440200: Setting aside a provision between connected persons
- INTM440201: Difference between accurate delineation and disregard
- INTM440210: Share options: general
- INTM440220: Share options: summary of treatment
- INTM440230: Share options: transfer pricing issues
- INTM440240: Share options: transfer pricing issues: other situations
- INTM440250: Share options: application of arbitrage receipts rule to provision of share plans
- INTM440260: Charities
- Close sectionINTM441000: Transfer Pricing - Transactions and Structures - Business Structures
- INTM441010: General overview
- INTM441020: Tax-efficient structures
- INTM441030: Transferring risk
- INTM441040: Marketing and distribution - commissionaires: overview
- INTM441050: Marketing and distribution - commissionaires: practicalities
- INTM441060: Marketing and distribution - commissionaires: evidence gathering
- INTM441070: Marketing and distribution - commissionaires: challenges
- INTM441080: Marketing and distribution - other structures
- INTM441090: Manufacturing: overview
- INTM441100: Manufacturing: arm's length reward
- INTM441110: Services
- INTM441120: Research and development
- INTM441130: Valuable intangibles
- INTM441140: Other legislation
- Close sectionINTM480000: Transfer pricing - operational guidance: contents
- Close sectionINTM480500: Introduction
- INTM480510: Scope of the original guidance
- INTM480520: Alternatives to consider before transfer pricing
- INTM480530: Giving transfer pricing advice to customers
- INTM480540: Real time working of transfer pricing issues (excluding thin capitalisation)
- INTM480550: Real time working of transfer pricing issues: thin capitalisation
- Close sectionINTM481000: Governance
- INTM481010: Introduction
- INTM481020: What types of enquiry are within the governance?
- INTM481030: The stages of an enquiry
- INTM481040: The selection stage
- INTM481050: The progress stage
- INTM481060: The resolution stage
- INTM481070: The Transfer Pricing Group
- INTM481080: Case teams and the wider transfer pricing community
- Close sectionINTM482000: Risk assessment
- INTM482010: Introduction
- INTM482020: Issues to consider before starting a transfer pricing enquiry: resources
- INTM482030: Issues to consider before starting a transfer pricing enquiry: tax at risk
- INTM482040: Transfer pricing risk indicators: general
- INTM482050: Transfer pricing risk indicators: effective tax rates
- INTM482060: Transfer pricing risk indicators: transfer pricing rules in other countries
- INTM482070: Transfer pricing risk indicators: comparing the results of the company and the group
- INTM482080: Transfer pricing risk indicators: losses over a number of years
- INTM482090: Transfer pricing risk indicators: payment of significant management or service fees
- INTM482100: Transfer pricing risk indicators: payment of royalties
- INTM482110: Transfer pricing risk indicators: ownership of intellectual property
- INTM482120: Transfer pricing risk indicators: business reorganisations
- INTM482130: Conducting a transfer pricing risk assessment: detailed process
- INTM482140: Conducting a transfer pricing risk assessment: review of information from other sources
- INTM482150: Conducting a transfer pricing risk assessment: lack of information
- INTM482160: Conducting a transfer pricing risk assessment: range of issues
- INTM482170: Summary and conclusions
- Close sectionINTM483000: Working an enquiry
- INTM483010: Opening the case
- INTM483020: Working the case
- INTM483030: Transfer pricing documentation
- INTM483040: Initial information request
- INTM483050: Dealing with the initial response
- INTM483060: Exchange of information
- INTM483070: Reaching a settlement
- INTM483080: How many years?
- INTM483090: Assessments and enquiry closure notices
- INTM483100: Interest
- INTM483110: Penalties
- INTM483120: Penalties: negligence or carelessness
- INTM483130: After the settlement
- Close sectionINTM484000: Examining transfer pricing reports
- INTM484010: Overview
- INTM484020: Report contents
- INTM484030: Legislation
- INTM484040: Information in a report - functional analysis
- INTM484050: What transactions are covered?
- INTM484060: OECD methodologies
- INTM484070: OECD methods
- INTM484080: Using other methods
- INTM484090: Arm's length range
- INTM484100: Dealing with global transfer pricing
- Close sectionINTM485000: Evidence gathering
- INTM485010: Overview
- INTM485020: Establish the facts
- INTM485021: Comparability Analysis
- INTM485022: Economically relevant characteristics
- INTM485023: Risk allocation
- INTM485024: Accurate delineation of the actual transaction: Full process
- INTM485030: Using the most appropriate method
- INTM485040: Using a test year
- INTM485050: Bargaining power
- INTM485060: Searching for comparables
- INTM485070: Searching for comparables: internal comparables
- INTM485080: Searching for comparables: public information
- INTM485090: Searching for comparables: UK or global companies?
- INTM485100: Searching for comparables: using commercial databases
- INTM485110: Searching for comparables: making adjustments to potential comparables
- INTM485120: Searching for comparables: range of results
- INTM485130: Industry standards
- INTM485140: General research
- Close sectionINTM486000: Interaction with indirect taxes
- Close sectionINTM489000: Derivation and destination tables
- Close sectionINTM489500: Diverted Profits Tax: contents
- INTM489510: Introduction and overview: contents
- INTM489580: Application of Diverted Profits Tax: contents
- INTM489830: Customer engagement with HMRC: contents
- INTM489880: Notification, charging and payment: contents
- INTM489976: Imposing a charge - procedure and governance: contents
- INTM489996: Appendix A - notification template guidance
- INTM489998: Appendix B - notification template
- Close sectionINTM480500: Introduction
- Close sectionINTM500000: Intra-group funding
- Close sectionINTM501000: Intra-group funding - legislation and case law
- Close sectionINTM502000: Intra-group funding - practical issues
- Close sectionINTM503000: Intra-group funding - ‘equity function’ arguments
- INTM503010: Overview
- INTM503020: Types of company
- INTM503030: Centralising the finance function - commercial considerations
- INTM503040: Centralising the finance function: tax considerations
- INTM503050: Risk assessment
- INTM503060: Thin capitalisation risk assessment
- INTM503070: Functional analysis
- INTM503080: Applying a transfer pricing method
- Close sectionINTM503100: Cash Pooling
- INTM503110: Introduction to cash pooling
- INTM503120: Legal and commercial arrangements
- INTM503130: Setting interest rates for participants on an arm's length basis
- INTM503140: Short term and long term balances held in the cash pool
- INTM503150: UK company as long term depositor in the cash pool
- INTM503160: UK company as long-term borrower in the cash pool
- INTM503170: UK company as the cash pool header
- INTM503180: UK company as the cash pool header and the arm's length principle
- INTM503190: Netting considerations
- INTM503200: Risk assessment/compliance checks
- Close sectionINTM504000: Double taxation treaties - Beneficial ownership
- Close sectionINTM510000: Thin capitalisation: practical guidance
- Close sectionINTM511000: Introduction
- Close sectionINTM512000: The Advance Thin Capitalisation Agreement process
- INTM512010: Introduction to the ATCA process and its governance
- INTM512020: When can an ATCA application be made, and what periods can it apply to?
- INTM512030: What types of transactions are within the ATCA regime?
- INTM512050: Presenting an ATCA application - information and analysis
- INTM512060: Role of Business, Assets & International
- INTM512070: Criteria for acceptance of an ATCA application
- INTM512075: Setting up an ATCA
- INTM512080: Withdrawing from the ATCA process
- INTM512100: Completing the process
- INTM512110: Renewing the ATCA
- Close sectionINTM513000: Opening a case
- INTM513010: Where the case begins
- INTM513020: Gathering preliminary information
- INTM513030: Reasons for not taking up a case
- INTM513040: Other issues and where to look for them
- INTM513050: Risk assessment - indicators of risk
- INTM513060: Origins and destinations of debt
- INTM513070: Pre-return enquiries - no informal comfort
- INTM513080: The opening meeting
- Close sectionINTM514000: Knowledge and negotiation
- Close sectionINTM515000: Measuring earnings
- INTM515010: Measuring borrowing capacity
- INTM515020: Earnings before interest and tax (EBIT)
- INTM515030: Earnings before interest, tax, depreciation and amortisation (EBITDA)
- INTM515040: The effect of depreciation
- INTM515050: The effect of amortisation
- INTM515060: Exceptional items and unforeseen events
- INTM515070: The effect of accounting issues
- Close sectionINTM516000: Interest cover - debt servicing
- INTM516010: What interest cover means
- INTM516020: Matters of interest
- INTM516025: Discounted debt and convertible debt
- INTM516030: Factors affecting the interest rate
- INTM516035: LIBOR (London Interbank Offered Rate)
- INTM516040: Other measures of interest cover: netting
- INTM516050: What is an acceptable arm's length standard?
- INTM516060: Example of an interest cover calculation
- INTM516070: Cash flow and cash flow covenants
- INTM516080: Measuring cashflow sufficiency to pay interest and repay capital
- Close sectionINTM517000: Measuring debt
- INTM517010: Debt-based ratios (gearing or leverage)
- INTM517020: What is debt?
- INTM517030: What is equity?
- INTM517040: What is an acceptable arm's length standard?
- INTM517050: The UK borrowing unit
- INTM517060: How the nature of the commercial activity influences the level of debt
- INTM517070: Private Finance Initiative (PFI) companies
- INTM517080: Groups/companies in expansion mode
- INTM517090: Groups/companies in acquisition mode
- INTM517100: Groups with mixed activities
- INTM517110: Example: the components of a debt: equity ratio calculation
- INTM517120: Adjusting debt calculations: netting off of debt
- INTM517130: Adjusting debt calculations: netting off of cash
- Close sectionINTM518000: Lending against asset values
- INTM518010: Lending against assets in general
- INTM518020: Lending against tangible assets - assets other than buildings and land
- INTM518030: Lending against tangible assets - land and buildings
- INTM518040: UK third-party practices - loan to value ratios in property lending
- INTM518050: UK third-party practices - interest rate margins in property lending
- INTM518060: Offshore property companies
- INTM518070: Property companies and the credit crisis
- INTM518080: Lending against intangible assets
- Close sectionINTM519000: Private equity
- INTM519010: What is private equity?
- INTM519020: Private equity buyout funding structures
- INTM519030: Typical debt elements of a private equity buyout
- INTM519035: Payments-in-kind (“PIK”) notes
- INTM519040: Applying the transfer pricing rules - “acting together”
- INTM519050: Issues to consider
- INTM519060: Risk assessment - the basics
- INTM519070: Working the case: third party loan agreements
- INTM519080: Working the case: other points
- Close sectionINTM520000: Creating agreements between HMRC and the group
- INTM520010: Introduction to the main features of the agreement
- INTM520020: Maximum amount of loan or facility
- INTM520030: Interest rate
- INTM520040: Length of the agreement
- INTM520050: Covenant conditions
- INTM520060: Consequences of a covenant breach
- INTM520070: Covenant breaches and unforeseen circumstances
- INTM520080: Monitoring conditions
- INTM520085: Statement of practice 01/12
- INTM520090: Example of an agreement - the model ATCA
- INTM520100: Example of an agreement: model ATCA - appendix 1 - interest cover ratio
- INTM520110: Example of an agreement: model ATCA - appendix 2 - gearing ratio
- INTM520120: Example of an agreement: model ATCA - appendix 3 - short accounting period
- INTM520130: Example of an agreement: model ATCA - commentary on the agreement
- INTM520140: Making a recommendation to the Double Taxation Treaty team on pre-ATCA cases
- Close sectionINTM521000: Breaches of agreements between HMRC and the group
- Close sectionINTM522000: Third party loan agreements
- Close sectionINTM523000: Accountancy issues
- INTM523100: Introduction: accountancy impact on thin capitalisation
- INTM523150: International Financial Reporting Standards (IFRS) and UK Generally Accepted Accounting Practice (UK GAAP)
- INTM523160: Acceptable GAAP for thin cap purposes
- INTM523170: Impact of accounting on loan agreements
- INTM523180: The change in the treatment of preference shares under IFRS
- INTM523210: FRS 17: the impact of pensions accounting on thin capitalisation
- INTM523220: FRS 17: defined benefits and defined contributions schemes
- INTM523250: FRS 17: retirement benefits - profit and loss account
- INTM523270: FRS 17: retirement benefits - impact of current service costs
- INTM523280: FRS 17: interest cost and expected rate of return on assets
- INTM523300: FRS 17: actuarial gains and losses
- INTM523310: FRS 17: non-recurring items (past service costs, settlements and curtailments)
- INTM523400: FRS 17: pension deficits and surpluses
- INTM523410: FRS 17: summary of the impact of FRS 17 on thin capitalisation
- INTM523420: FRS 17: presentation of FRS 17 in the accounts - disclosures
- Close sectionINTM524000: Loan pricing and the use of credit ratings
- INTM524010: What is a credit rating?
- INTM524020: How do ratings agencies arrive at their ratings?
- INTM524030: What are credit ratings used for by the market?
- INTM524040: Investment grade and non-investment grade credit ratings
- INTM524050: The distinction between ‘investment grade’ and ‘speculative grade’
- INTM524060: Important factors to consider when using credit ratings in loan pricing cases
- INTM524070: In-house credit ratings
- INTM524080: Extension of the use of credit ratings to thin capitalisation cases
- INTM539000: Finance glossary
- Close sectionINTM550000: Hybrids: contents
- Close sectionINTM550010: Introduction: contents
- INTM550020: What is a hybrid or other mismatch
- INTM550030: Examples of hybrid mismatches
- INTM550040: Scope of Part 6A, TIOPA 2010
- INTM550050: Why was legislation introduced
- INTM550060: Overview of legislation
- INTM550070: When does the legislation take effect
- INTM550080: Interaction with other legislation
- INTM550085: Interaction with transfer pricing legislation
- INTM550086: Examples of interaction with transfer pricing
- INTM550090: Summary of Part 6A
- INTM550095: Legislative changes since 1 January 2017
- INTM550100: Hybrid and other mismatch structures within Part 6A - example
- Close sectionINTM550500: Definition of key terms: contents
- INTM550510: Arrangements within the scope of Part 6A
- INTM550520: Meaning of tax
- INTM550530: Equivalent provision under the law of a territory outside the United Kingdom
- INTM550540: Payment and quasi-payment, securitisation companies
- INTM550550: Payer and payee
- INTM550560: Ordinary income
- INTM550570: Ordinary income of controlled foreign companies
- INTM550580: Hybrid entities, residence, investors and investor jurisdiction
- INTM550590: Permanent establishment
- INTM550600: Financial instruments and relevant investment funds
- INTM550610: Control groups and related persons
- INTM550620: 50% investment and 25% investment
- INTM550630: Partnership and partnership members
- INTM550640: Reasonable to suppose
- INTM550650: Structured arrangements
- INTM550660: Summary
- Close sectionINTM551000: Financial instruments (Chapter 3): contents
- INTM551010: Overview: contents
- INTM551070: Conditions to be satisfied: contents
- INTM551120: Extent of the mismatch
- INTM551130: Extent of the mismatch - case 1
- INTM551140: Extent of the mismatch - case 2
- INTM551150: Timing - permitted taxable period
- INTM551160: Counteraction
- INTM551170: Counteraction and distribution exemption rules
- INTM551180: Examples
- Close sectionINTM552000: Hybrid transfers (Chapter 4): contents
- INTM552010: Overview
- INTM552020: Conditions to be satisfied: contents
- INTM552160: The extent of the mismatch
- INTM552165: The extent of the mismatch - example
- INTM552170: The financial trader exclusion - overview
- INTM552175: The financial trader exclusion - conditions to be satisfied: contents
- INTM552210: Payments to relevant investment funds
- INTM552220: Counteraction - UK payer
- INTM552230: Counteraction - UK payee
- INTM552400: Examples
- Close sectionINTM553000: Hybrid payer (Chapter 5): contents
- Close sectionINTM554000: Transfers by UK permanent establishment of a multinational company (Chapter 6): contents
- Close sectionINTM555000: Hybrid payee (Chapter 7): contents
- INTM555010: Overview
- INTM555020: Conditions to be satisfied: contents
- INTM555080: Extent of the mismatch - general
- INTM555090: Extent of the mismatch - hybrid payee not chargeable to tax in any territory
- INTM555095: Extent of the mismatch - hybrid payee is a partnership or relevant transparent entity
- INTM555100: Counteraction: contents
- INTM555200: Examples
- Close sectionINTM556000: Multinational payee (Chapter 8): contents
- Close sectionINTM557000: Hybrid entity double deduction mismatches (Chapter 9): contents
- INTM557010: Overview
- INTM557020: Conditions to be satisfied: contents
- INTM557060: Counteraction
- INTM557070: Counteraction - investor in hybrid entity
- INTM557075: Counteraction - hybrid entity
- INTM557080: Stranded deductions
- INTM557085: Hybrid entity within the charge to CT - Capital Allowances
- INTM557190: Examples
- Close sectionINTM558000: Dual territory double deduction (Chapter 10): contents
- Close sectionINTM559000: Imported mismatches (Chapter 11): contents
- Close sectionINTM561100: Other provisions - adjustments in light of subsequent events: contents
- Close sectionINTM561200: Allocation of DII within a group: contents
- INTM561500: Other provisions - anti-avoidance
- INTM561600: Special provision concerning transparent funds
- INTM561650: Special provision concerning transparent funds - structured arrangements
- Close sectionINTM561700: Operational guidance: contents
- Close sectionINTM550010: Introduction: contents
- Close sectionINTM590000: Arbitrage - legislation and principles
- Close sectionINTM594500: Introduction
- Close sectionINTM595000: Deductions
- INTM595010: Persons affected by the deduction rules
- INTM595020: Rule A - expenses deducted more than once
- INTM595030: Rule B - deduction not matched by a taxable receipt
- INTM595040: Four conditions to be met for rules A and B to apply
- INTM595050: Condition A: what is a scheme?
- INTM595060: Condition B: deduction for Corporation Tax
- INTM595070: Condition C: the main or a main purpose of achieving a UK tax advantage
- INTM595075: Condition C: examples
- INTM595080: Condition D: meaning of minimal
- INTM595090: Interaction with thin capitalisation agreements
- INTM595100: Interaction with other legislation
- INTM595110: Disclaiming a deduction
- Close sectionINTM595500: Receipts
- INTM595510: Aim and effect of the legislation
- INTM595520: Five conditions need to be met for the receipts rule to apply
- INTM595530: Receipts rule conditions
- INTM595540: Meaning of scheme for receipts cases
- INTM595550: What is reasonable expectation?
- INTM595560: What is a contribution to the capital of a company?
- INTM595570: Role of the receipts rule in reinforcing other financial avoidance rules
- Close sectionINTM596000: Qualifying schemes for deductions cases
- Close sectionINTM596500: Procedures
- Close sectionINTM597000: Arbitrage: practical guidance
- Close sectionINTM597500: Case identification and working of enquiries
- Close sectionINTM598000: Examples demonstrating the application of the arbitrage legislation
- INTM598010: Example 1 Part 1 - inward investment
- INTM598020: Example 1 Part 2 - inward investment
- INTM598030: Example 1 Part 3 - inward investment
- INTM598040: Example 2 Part 1 - outward investment
- INTM598050: Example 2 Part 2 - outward investment
- INTM598060: Example 2 Part 3 - outward investment
- INTM598070: Example 2 Part 4 - outward investment
- INTM598080: Example 3 Part 1 - subordinated debt
- INTM598090: Example 3 Part 2 - subordinated debt
- INTM598100: Example 4 Part 1 - debt restructuring
- INTM598110: Example 4 Part 2 - debt restructuring
- INTM598120: Example 5 Part 1 - dividends
- INTM598130: Example 5 Part 2 - dividends
- INTM598140: Example 6 - receipts legislation - deferred subscription
- INTM598150: Example 7 - Controlled Foreign Company restructuring
- INTM598160: Example 8 - convertible securities
- INTM598170: Example 9 - hybrid entity definition
- Close sectionINTM600000: Transfer of assets abroad
- INTM600010: Introduction
- INTM600020: Overview of ITA 2007, s 720 & ITA 2007, s 727
- INTM600030: Overview of ITA 2007, s 731
- INTM600040: Overview of ITA 2007, s 736 - 742 exemption
- INTM600050: Mandatory referral to WMBC Assets Edinburgh
- INTM600060: Checklist of indicators
- INTM600070: What information is needed by the WMBC Assets Edinburgh
- INTM600080: Working transfer of assets enquiries with CAR Trusts & Estates Bootle
- Close sectionINTM610000: Contents: Profit Fragmentation Rules
- INTM610010: Introduction
- INTM610020: How will these rules be used?
- INTM610030: When do these rules apply?
- INTM610040: Parties
- INTM610050: Parties (Continued)
- INTM610060: Profit Fragmentation Arrangements
- INTM610070: The Material Provision
- INTM610080: Transfer of Value
- INTM610090: Tracing Value
- INTM610100: Arm's Length Transfer
- INTM610110: Enjoyment Conditions
- INTM610120: Enjoyment Test
- INTM610130: Procurer Test
- INTM610140: Exception Conditions
- INTM610150: Tax Mismatch
- INTM610160: Quantifying the Resident Party's Tax Reduction
- INTM610170: Qualifying Deduction and Qualifying Loss Relief
- INTM610180: Hybrid and Transparent Entities/ Reasonable to Conclude/ UK Resident Non-Domiciled Individuals
- INTM610190: Tax Advantage Test
- INTM610200: Profit Fragmentation Adjustments
- INTM610210: Hierarchy of Legislation
- INTM610220: NICs Consequences for Individuals
- INTM610230: Reimbursement Payments
- INTM610240: Double Taxation
- INTM610250: Income Chargeable to ITA 2007, s 720 or ITA 2007, s 727
- INTM610260: Income Chargeable to ITA 2007, s 731
- INTM610270: Carried Interest and Disguised Investment Management Fees
- INTM610280: Making Adjustment on the Tax Return: Individuals
- INTM610290: Members of a partnership
- INTM610300: Companies required to make adjustments
- Close sectionINTM620000: ORIP:Contents
- INTM620100: Introduction to ORIP: Contents
- INTM620200: Charge to tax on ORIP: Contents
- INTM620300: Exemptions: Contents
- INTM620400: Recovery of tax from related persons: Contents
- INTM620420: Payment Notice: Contents
- INTM620500: General: Contents
- INTM620600: Process and procedures: Contents
- INTM620700: Glossary of terms: Contents
- Close sectionINTM630000: Royalty Withholding
- INTM630100: Background
- Close sectionINTM630200: Anti Treaty Shopping Rules
- Close sectionINTM630300: Definition of a royalty
- Close sectionINTM630400: UK Source
- INTM630410: UK Source: Overview
- INTM630420: UK Source: Commencement
- INTM630430: In connection with a trade carried on by the permanent establishment
- INTM630440: UK Source: Amount of the royalty with a UK source
- INTM630450: UK Source: Arrangements seeking to obtain a foreign DTA advantage
- INTM630460: UK Source: Examples
- Close sectionINTM630500: Interaction with Diverted Profits Tax
- INTM630510: UK Source: Interaction with Diverted Profits Tax: Overview
- INTM630520: UK Source: Interaction with Diverted Profits Tax: Commencement
- INTM630530: Credit for UK or foreign tax on the same profits - general rules
- INTM630540: Relief if amount included in relevant taxable income of a connected party
- INTM630550: Relief under Double Taxation Agreements
- INTM630560: Examples
- Close sectionINTM650000: Distribution exemption
- Close sectionINTM651000: Overview
- Close sectionINTM652000: Exemption for small companies
- Close sectionINTM653000: Exemption for all other companies
- INTM653010: Outline
- INTM653020: Exempt classes
- INTM653030: Controlled companies
- INTM653040: Non-redeemable ordinary shares
- INTM653050: Meaning of “ordinary shares”
- INTM653060: Those that do not issue shares
- INTM653070: Meaning of “redeemable”
- INTM653080: Portfolio holdings
- INTM653090: Transactions not designed to reduce tax
- INTM653100: Relevant profits
- INTM653110: Series of transactions
- INTM653120: Shares accounted for as liabilities
- Close sectionINTM654000: Anti-avoidance legislation
- INTM654010: Outline
- INTM654020: Manipulation of controlled company rules
- INTM654030: Manipulation of controlled company rules: purpose test
- INTM654040: Quasi-preference or quasi-redeemable shares
- INTM654050: Manipulation of portfolio holdings rule
- INTM654060: Loan relationships schemes
- INTM654070: Deductions schemes
- INTM654080: Payments for distributions
- INTM654090: Payments not at arm's length
- INTM654100: Diversion of trade income
- Close sectionINTM655000: Interpretation
- INTM655010: Election that a distribution should not be exempt
- INTM655020: Underlying tax
- INTM655030: Acceptable distribution policy dividends
- INTM655040: Manufactured dividends
- INTM655050: Franked investment income
- INTM655060: Management expenses
- INTM655070: Certain non-dividend distributions
- INTM655080: Life insurance companies
- INTM655090: General insurance companies and Lloyds
- Close sectionINTM700000: International movements of capital
- INTM700100: Overview
- INTM700110: Previous rules
- INTM700200: Repeal of the Treasury Consents regime
- INTM700300: Reporting requirement
- INTM700310: International movements of capital: Reporting requirement: where should reports be sent?
- INTM700400: Who should make reports?
- INTM700500: Nomination arrangements
- INTM700600: What is reportable?
- INTM700700: Exclusions from the reporting requirement
- INTM700710: Exclusions: cash pooling arrangements
- INTM700720: Exclusions: issue of shares and debentures
- INTM700730: Exclusions: transfers of shares and debentures
- INTM700800: What information should the report include?
- INTM700900: Valuing transactions
- INTM701000: Other provisions
- INTM701100: Commencement
- INTM701200: Regulations
- Close sectionINTM800000: Technical guidance for Swiss/UK Tax Cooperation Agreement
- INTM850000: Hybrid and other mismatches
- Close sectionINTM860000: Immunities and Privileges
- INTM860100: Immunities and Privileges Overview
- INTM860150: Crown Immunity
- INTM860180: Sovereign Immunity
- INTM860200: Diplomatic Immunity
- INTM860210: Diplomatic Missions: general
- INTM860220: Diplomatic Missions: conditions of exemption
- INTM860230: Diplomatic Missions: exemptions from Income Tax
- INTM860240: Diplomatic Missions: exemption from Capital Gains Tax
- INTM860250: Diplomatic Missions: Pensions
- INTM860260: Diplomatic Missions: Communicating with privileged persons
- INTM860270: Diplomatic Missions: Self-Assessment returns
- INTM860280: Diplomatic Missions: personal allowance
- INTM860290: Diplomatic Missions: official/other emoluments
- INTM860300: Consuls: Consular Relations Act 1968
- INTM860310: Exemptions from Income Tax
- INTM860320: Exemptions from Capital Gains Tax
- INTM860330: Extension of Tax Privileges
- INTM860340: Exemption: consuls/ other official agents
- INTM860350: Pensions
- INTM860360: Representatives of Overseas Governments: foreign consuls and their staffs: Particulars about Commonwealth Citizens
- INTM860370: Immunity from legal process
- INTM860380: Self-Assessment Returns
- INTM860410: Agents-General
- INTM860420: Staff of Agents-General/Official Agents
- INTM860430: Certificates Issued; Agents General
- INTM860440: Commonwealth Country Military Officers
- INTM860450: Commonwealth Countries and Republic of Ireland (Immunities/Privileges) Order 1971
- INTM860500: Official Agents
- INTM860510: “New Agencies” or departments
- INTM860520: Employers not entitled to exemption
- INTM860530: Tax Returns
- INTM860540: Exemption in doubt
- INTM860600: Visiting Forces
- INTM860610: Forces of other countries stationed in UK: NATO Headquarters employees
- INTM860620: Forces of other countries stationed in UK: claims to exemption
- INTM860630: Forces of other countries stationed in UK: residence status
- INTM860640: Forces of other countries stationed in UK: submission for Advice
- INTM860700: International Organisations
- INTM860710: International organisations: Procedure: how to deal with claims
- INTM860720: Employees of international organisations: claims by individuals
- INTM860730: Employees of International Organisations: Previous claims by individuals
- INTM860740: Employees of International Organisations: Staff based in the UK
- INTM860750: Employees of International Organisations: Where exemption does not apply - Special cases
- INTM860760: Employees of International Organisations: Experts/consultants
- INTM860770: Employees of International Organisations: What to do where exemption does not apply
- INTM860780: Employees of International Organisations: Treatment of pensions
- INTM860800: European Union (EU): General Exemption
- INTM860810: European Union: exemption from Taxation
- INTM860820: European Union: exemption of staff
- INTM860830: European Union: Limit of exemption
- INTM860840: European Union: procedures: how to give exemption
- INTM860850: European Union: procedures: how to exempt EU staff
- INTM860860: European Union: procedures: Staff based in the UK
- INTM860870: European Union: procedures: Other income