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Vol 23 No 5 May/June 2018

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Drafting Commercial Agreements

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Taxation of Non-United Kingdom Resident Companies and their Shareholders

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ISBN13: 9781901614046
ISBN: 1901614042
Published: October 2002
Publisher: Key Haven Publications PLC
Country of Publication: UK
Format: Hardback
Price: £175.00

Despatched in 8 to 10 days.

This long awaited work, written by one of the renowned tax specialists in the redoubtable Revenue Chambers at 24 Old Buildings, Lincoln’s Inn, will prove a unique and invaluable guide to all practitioners concerned with the taxation of non-United Kingdom resident companies and their shareholders.

Stephen Brandon’s opus is sure to become as great an offshore classic as the Non-Resident Trusts and Foreign Domiciliaries of his chambers colleague, Robert Venables Q.C.

Income and gains are now considered in the context of the overall tax profile of a structure, so that the positions (where relevant) of company, trustees and United Kingdom resident individuals are drawn together. The emphasis throughout is on explaining the conceptual basis behind the tax charge and moving from that to practical tax planning.

Despite the depth of analysis, the book is written in a very readable style and its structure and cross-referencing make it easy to follow. A detailed analysis of some areas, which cannot be found elsewhere, is given, e.g. The authorities determining whether or not a receipt from a foreign company is income or capital.

Areas covered include:

  • Avoidance of United Kingdom Residence
  • Planning to Avoid Income
  • Situs of Assets
  • Ramsay and Foreign companies
  • Practical Treaty Relief
  • Trading through Branches/Permanent Establishments
  • Investment Companies
  • Foreign Domiciliaries (including ITA 1988, section 146 and United Kingdom homes)
  • Unwinding Inefficient Structures
  • ICTA 1988, section 703 (and interrelation with section 739)
  • TCGA 1992, section 13 and its Mitigation
  • Section 739
  • Migrant companies
  • Compliance after Dimsey

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