Corporation Tax

What are connected companies for loan relationship purposes ― practical approach Produced by a Tolley Corporation Tax expertCorporation TaxGuidanceBrief overview of the rules The loan relationships legislation applies to any 'money debt' arising from the lending of money entered into by a company, either as a lender or borrower. The rules are contained in CTA 2009, ss 292–569 (Pts 5 and 6).Broadly, the tax treatment of loan relationship-related debits and credits is based on the amounts reflected in profit and loss in the company's accounts (under GAAP), with debits generally being allowable and credits being taxable. However, there are a number of exceptions to this general rule. One of the most important exceptions is where the relevant loan relationship is between 'connected companies'. For connected companies, any loan relationship debits are generally not allowable and any loan relationship credits are treated as not taxable. Connected companies are also prevented from using fair value accounting and must use amortised cost basis accounting for their loan relationships. In addition, another potential consequence of a release between two companies is that this can result in a deemedContinue reading the full document To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+TM. TAKE A FREE TRIAL NOW. Existing user? Sign-in hereTax on UK resident beneficiaries of non-resident trusts ― overview Tax on UK resident beneficiaries of non-resident trusts ― overview Introduction UK resident beneficiaries of non-resident trusts are subject to UK tax on payments or benefits received from the trust. They are liable for income tax on income distributions from the trust and they may also be liable to14 Jul 2020 13:47 | Produced by Tolley Read moreEmployment TaxIncome tax paid on behalf of employee Income tax paid on behalf of employee Introduction Employers may wish to make payments of employment income to an employee / director without the employee suffering a tax or NIC cost on that pay. In other words, the employer wants to pay an amount net of tax and NIC. In some instances, often with14 Jul 2020 11:58 | Produced by Tolley in association with Paul Tew Read moreValue Added TaxHolding companies ― VAT status of activities Holding companies ― VAT status of activities This guidance note examines how to determine the VAT status of a holding company's activities. In particular, it looks at: when a holding company is or is not in business; if a holding company is in business, whether its activities are exempt or taxable. The14 Jul 2020 17:13 | Produced by Tolley Read more#J-18808-Ljbffr