International Tax Planning Using UK Companies expands and updates UK International Holding Companies. The book examines the potential of the UK company as an offshore vehicle for use by offshore trust companies, entrepreneurs, finance directors and their lawyers and accountants. It also assesses the international tax planning opportunities of the new foreign dividend exemption introduced in July 2009 which further consolidate the UK’s standing as one of the most tax-efficient corporate domiciles.
In addition the book examines the substantial shareholder exemption introduced for capital gains (first introduced in 2002) as well as the tax benefits of the UK company as an international trading company and as a recipient of various kinds of non-UK source revenue. It also explains the relevant EU and UK legislation, the operation of double tax treaties, and case study examples illustrating offshore tax planning possibilities using UK companies. Also includes:
- Foreign withholding taxes
- The new taxation exemption for foreign dividends with reference to the new inclusion of capital dividends
- Company residence, including reference to the 2010 UK Court of Appeal case of Smallwood
- UK withholding tax and UK dividends, royalties and interest payments
- Tax exemption for capital gains
- Anti-avoidance, including reference to the UK Thin Capitalisation GLO
- Other uses of UK companies, LLPs and Limited Partnerships in international tax planning
- UK trusts and trustees
- UK company formation and administration with updates arising from the UK Companies Act 2006
Appendices include full text of the foreign dividend and substantial shareholder exemptions.
International Tax Planning Using UK Companies is essential reading for corporate and tax lawyers and accountants in the UK and overseas, finance directors of large UK overseas companies, and offshore trust companies.
