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23 Cards in this Set
- Front
- Back
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In the transfer of trade in 75% group, how are CAs transferred? |
At the TWDV |
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VAT groups - partially exempt trading companies |
Will make the group partially exempt too |
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Branch basis of charge for CT |
Extension of UK resident company so all profits assessed as UK trading profits Can make irrevocable election to exempt from tax in the UK |
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Overseas sub basis of charge |
Remitted to UK as interest/property income UK CT Or as dividends NO UK CT |
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Branch CAs |
Available on overseas assets unless election made |
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Overseas sub CAs |
Not available |
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Branch trading loss relief |
Can relieve against UK profits Unless election made |
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Overseas sub trading losses |
No surrendering of trading losses |
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Branch chargeable gains |
ROR available |
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Overseas sub Chargeable gains |
No ROR available |
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Branch impact on tax payment dates |
None Treated as a separate entity |
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Overseas sub impact on tax oayment dayes |
51% sub so share threshold of £1.5m with group |
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Branch election |
1. Applies to all branches 2. Irrevocable 3. Made at any time 4. Effective from next start of AP |
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CFCs definition |
Non Uk resident company controlled by UK individuals and or companies with artificially diverted profits from the UK |
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Exemptions to CFC charge |
Exemption period - 12 ms of company coming into control of UK residents Exempt territory list from HMRC Low profits - <500k in 12ms and <50k non trading profits Low profit margin - <10% of pperating expenditure Tax rate - if 75% of UK tax |
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When does CFC charge arise? |
When UK company owns >25% interest And CFC has chargeable profits |
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How to calc CFC charge |
UK portion of profits * UK tax rate |
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Tenporary non resident |
If UK resident for 4 of previous 7 tax years: will be liable to CGT if returning in next 5 years |
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Partial exemption test 1 |
1. Total input tax less than £625 per month? And 2. Exempt TO less than 50% or total TO? Yes = totally recoverable |
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Partial exemption test 2 |
1. Total input tax - input tax on taxable supplies less than £625 per month? And 2. Exempt TO less than total TO? Yes = totally recoverable |
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Calculation of reclaimable portion for non attributable input VAT |
Non attributable input tax * (taxable TO/total TO) |
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Capital Goods Scheme annual adjustment calc |
Stops manipulation of % If changes: Total input VAT/ years (% difference) = paid every year for period |
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Incorporation relief conditions |
1. Going concern 2. All assets except cash transferred 3. Consideration wholly or partly in shares |
