International Tax Planning Using UK Companies

The UK's Companies Act 2006, together with the new rules regarding foreign tax credits and exemptions, present a seismic change for holding companies in the UK. These changes further consolidate the UK's standing as one of the most tax-effective jurisdictions in which to establish an international holding company. This book analyzes the tax advantages enjoyed by such companies. It explains the new regime, comparing advantages and disadvantages of a UK holding company with those of other jurisdictions, and provides an outline of the formation and administration issues. This second edition has been thoroughly updated to cover Cyprus as an international holding company location, changes to the local taxation of foreign dividends, company residence and the effects of Wood v Holden, and other uses of UK companies in tax planning. The book includes relevant EU and UK legislation, as well as case study examples illustrating the new rules and tax planning possibilities. Contents include: foreign withholding taxes - local taxation of foreign dividends - company residence - UK withholding tax and UK dividends - tax exemption for capital gains - anti-avoidance - UK company formation and administration - other uses of UK companies in international tax planning arrangements.