Uk Corporation tax for foreign subsiduary

annab1 · Postby **annab1** » Sun Mar 16, 2008 11:52 am

Does anyone know the test for determining whether a new company in a group is a resident in the uk for corporation tax purposes if the the parent company operates worldwide? I believe it involves a controld test.
and also does anyone know any steps that can help to avoid the new company being subject to corporation tax in the UK?

leedsCIMAstudent · Postby **leedsCIMAstudent** » Mon Mar 17, 2008 4:53 am

Is there a PE (Permanent Establishment)?

What is the nature of the activities that this specific company (or its overseas employees) undertake that pertains to the UK? What does the group as a whole do?

annab1 · Postby **annab1** » Tue Mar 18, 2008 2:26 am

Hi
My questions is a research question for a fake company and unfortunately i have not been told exactly what the parent company does apart from that it is a worldwide corporation and intends to form 6 new companies (subsiduaries) but would like to make sure that one will be exempt for UK corporation tax. I have looked on the hmrc website and i have a feeling that the test is a control test, i.e the less control the UK parent company has over the new subsiduary, the less chance it will be deemed to be a UK company for corporation tax purposes. However I am unsure and do not know what steps could be taken to avoid tax. Any further help you could provide would be much appreciated.
Thanks