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Contents

Official guidance
Company Taxation Manual

CTM34500 · Residence: dual resident companies

  • CTM34505 · Introduction
  • CTM34510 · Legislation
  • CTM34530 · Definition
  • CTM34560 · Definition - investing company
  • CTM34590 · Advice from Head Office
  • CTM34600 · Anti-avoidance - limitation of group relief
  • CTM34610 · Anti-avoidance - limitation of loss relief
  • CTM34620 · Anti-avoidance - limitation of other reliefs
  • CTM34700 · Accounting periods straddling 1 April 1987
  • CTM34710 · Accounting periods straddling 1 April 1987: apportionment of losses
  • CTM34720 · Anti-forestalling provisions
  • CTM34730 · Early payment of charges on income
  • CTM34740 · Early payment of interest
  • CTM34750 · Board's direction
  • CTM34760 · Group reorganisations
  • CTM34770 · Reports to Business International
  1. Residence: dual resident companies: contents
  2. Residence: dual resident companies: reports to Business International

CTM34770 | Residence: dual resident companies: reports to Business International

From HM Revenue & Customs · Company Taxation Manual

Report to the Base Protection Team in BAI any case where it appears that attempts are being made to retain advantages to the group in the UK and overseas similar to those previously provided by dual resident investing companies. For example, groups may arrange their affairs so that substantial interest payments are made either in the UK or overseas which are balanced by income arising in low tax jurisdictions.

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