No Withholding Tax
The UK does not impose withholding tax on the distribution of dividends to shareholders or parent companies, regardless of where the shareholder is resident in the world.
Sale of Shares in the Holding Company
The UK does not charge capital gains tax on the sale of assets situated in the UK (other than UK residential property) held by non-residents of the UK.
Since April 2016 UK residents have paid capital gains tax on share disposals at a rate of 10% or 20%, depending on whether they are basic or higher rate taxpayers.
Capital Duty
In the UK there is no capital duty on paid up or issued share capital. Stamp duty at 0.5% is, however, payable on subsequent transfers.
There is no minimum paid up share capital for normal limited companies in the UK.
In the event that a client wishes to use a public company, the minimum oman mobile database issued share capital is £50,000, of which 25% must be paid up. Public companies are generally only used for substantial activities.
Overseas Branches
A company may elect to exempt from UK corporation tax all of the profits of its overseas branches that are involved in active operating business. If this election is made, branch losses may not be offset against UK profits.
Controlled Foreign Company Rules
Controlled Foreign Company Rules (CFC) are intended to apply only where profits have been artificially diverted from the UK.
Subsidiaries in jurisdictions detailed on a wide list of excluded territories are generally exempt from CFC taxation if less than 10% of the income generated in that territory is exempt from or benefits from a notional interest deduction.
Profit, other than interest income, in all remaining companies is only subject to a CFC charge if a majority of the business functions relating to assets used or risks borne are performed in the UK; even then only if taxed at an effective rate less than 75% of the UK rate.
No Minimum Paid up Share Capital
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