ÀÏ˾»úÎçÒ¹¸£Àû

Tax News

Treasury consults on narrowing scope of sovereign immunity from direct taxation

Published on: 05 July 2022
Published by a

Specialist Tax Regulatory Materials

Article summary

In a new consultation, the UK government proposes to codify and narrow the tax exemption for foreign sovereign persons, limiting exemption to investment income only and potentially bringing income from other activities within the scope of UK taxation.

Jurisdiction(s): England, Northern Ireland, Scotland and Wales

Popular Articles

Wholly and exclusively

Wholly and exclusivelyFor both income tax and corporation tax purposes, one of the fundamental conditions that must be satisfied for an item of expenditure to be deductible, is that it must incurred ‘wholly and exclusively’ for the purposes of the trade, profession or vocation. References to CTA

14 Jul 2020 14:00 | Produced by Tolley Read more Read more

Double tax relief

Double tax reliefWhen income arises in a foreign country to a UK resident company and that income is taxable in that foreign country, the UK may give the company relief for the foreign tax by crediting the foreign tax against the UK tax charged on that income. This might include withholding tax on

14 Jul 2020 11:31 | Produced by Tolley in association with Anne Fairpo Read more Read more

Corporate interest restriction ― administrative aspects

Corporate interest restriction ― administrative aspectsThe corporate interest restriction (CIR) regime has some specific administrative rules in addition to the general administrative requirements for corporation tax returns. This guidance note does not include commentary on provisions that are

14 Jul 2020 11:19 | Produced by Tolley Read more Read more