UK mobile phone numbers are not preceded by a city code. When dialing these numbers from within the United Kingdom, a zero must be added as a prefix.
London GMT
Ernst & Young LLP
+44 (20) 7951-2000
1 More London Place Fax: +44 (20) 7951-1345 London SE1 2AF England
Principal Tax Contacts
Jeff Soar, +44 (20) 7951-6421 Head of Tax for United Kingdom Mobile: +44 7786-118-669 and Ireland Email: jsoar@uk.ey.com
Laura Mair, +44 (141) 226-7423 Tax Markets Leader for Mobile: +44 7467-441-355 United Kingdom and Ireland Email: lmair@uk.ey.com
Anna Anthony, Head of Tax for +44 (20) 7951-4165 Financial Services for EMEIA Mobile: +44 7920-534-086 Email: aanthony@uk.ey.com
Angela Dawes, Head of Tax +44 (20) 7951-2760 for UK Financial Services Mobile: +44 7956-364-147 Email: adawes@uk.ey.com
International Tax and Transaction Services – International Corporate Tax Advisory
Anna Anthony, +44 (20) 7951-4165 Financial Services Mobile: +44 7920-534-086 Email: aanthony@uk.ey.com
Ian Beer, Technology, Media +44 (20) 7980-9060 and Telecommunications Mobile: +44 7768-747-479 Email: ibeer@uk.ey.com
Jenny Coletta, +44 (20) 7951-5993 Financial Services Mobile: +44 7824-868-847 Email: jcoletta@uk.ey.com
Paul D’Arcy
+44 (20) 7951-4660 Mobile: +44 7785-325-256 Email: pdarcy@uk.ey.com
David Evans +44 (20) 7951-4246 Mobile: +44 7880-913-412 Email: devans@uk.ey.com
Russell Gardner, Real Estate, +44 (20) 7951-5947 Hospitality and Construction Mobile: +44 7740-378-833 Email: rgardner1@uk.ey.com
Lawrence Hall
+44 (118) 928-1321
Mobile: +44 7880-787-881 Email: lhall11@uk.ey.com
Robert Hodges, Mining & Metals, +44 (20) 7951-7205 Oil & Gas and Power & Utilities Email: rhodges@uk.ey.com
Claire Hooper
+44 (20) 7951-2486 Email: chooper@uk.ey.com
Tony Jones +44 (20) 7951-9527 Mobile: +44 7717-571-155 Email: tjones@uk.ey.com
Jason Lester
+44 (20) 7951-0884
Mobile: +44 7765-240-483 Email: jlester1@uk.ey.com
Amber Mace +44 (20) 7951-6154 Mobile: +44 7917-502-671 Email: amace1@uk.ey.com
Matthew Mealey, Global Content +44 (20) 7951-0739
Innovation Leader
Megha Menon
Mobile: +44 7717-888-825 Email: mmealey@uk.ey.com
+44 (20) 7951-4772
Mobile: +44 7795-886-827 Email: mmenon@uk.ey.com
Mike Michael +44 (20) 7980-9636
Mobile: +44 7920-530-188 Email: mmichael@uk.ey.com
Richard Milnes, +44 (20) 7951-7750
Financial Services Mobile: +44 7831-137-202 Email: rmilnes@uk.ey.com
Matthew Newnes +44 (20) 7951-3273 Email: mnewnes@uk.ey.com
Andrew Ogram
+44 (20) 7951-1313
Mobile: +44 7771-642-433 Email: aogram@uk.ey.com
Colin Pearson +44 (20) 7980-0994 Mobile: +44 7799-476-563 Email: cpearson1@uk.ey.com
Mark Persoff, +44 (20) 7951-9400 Financial Services Mobile: +44 7717-693-782 Email: mpersoff@uk.ey.com
Daniel Rees +1 (212) 360-9507 (resident in New York) Mobile: +1 (475) 619-0042 Email: daniel.w.rees1@ey.com
Richard Ross, Real Estate, +44 (20) 7783-0049 Hospitality and Construction Email: rross1@uk.ey.com Jason Short +44 (20) 7951-1769 Mobile: +44 7880-787-367 Email: jshort@uk.ey.com
Tim Steel +44 (20) 7951-1149 Mobile: +44 7769-886-409 Email: tsteel@uk.ey.com
Jo Stobbs +44 (20) 7980-0587 Email: jstobbs@uk.ey.com
Neil Strathdee, Mining & Metals, +44 (20) 7951-4017 Oil & Gas and Power & Utilities Mobile: +44 7896-970-117 Email: nstrathdee@uk.ey.com
James Taylor, International Tax +44 (20) 7951-0129 and Transaction Services Leader for Mobile: +44 7919-210-738 United Kingdom and Ireland Email: jtaylor3@uk.ey.com Daniel Thompson, +44 (20) 7951-0144 Financial Services Mobile: +44 7886-400-599 Email: dthompson2@uk.ey.com
Fiona Thomson
+44 (20) 7951-3913 Email: fthomson@uk.ey.com
Duncan Whitecross +44 (20) 7951-5123 Mobile: +44 7785-556-819 Email: dwhitecross@uk.ey.com
David Wilkinson +44 (20) 7951-7040 Email: dwilkinson1@uk.ey.com
International Tax and Transaction Services – Transaction Tax Advisory
Jonathan Anderson, International Tax +44 (20) 7951-4863 and Transaction Services – Transaction Mobile: +44 7748-133-318
Tax Advisory Leader for Email: janderson@uk.ey.com United Kingdom and Ireland
Sue Anderson
+44 (20) 7951-4252
Mobile: +44 7900-405-371 Email: sanderson@uk.ey.com
Mark Boyle, +44 (20) 7951-2626
Transaction Tax Leader for Mobile: +44 7976-159-434 Financial Services for EMEIA Email: mboyle@uk.ey.com
Julian Broughton
+44 (20) 7951-7947
Mobile: +44 7932-041-985 Email: jbroughton@uk.ey.com
Richard Clarke +44 (20) 7951-6451
Mobile: +44 7920-581-524 Email: rclarke2@uk.ey.com
Daniel Eyre
+44 (20) 7951-5176
Mobile: +44 7957-391-717 Email: deyre@uk.ey.com
Tim Goodman +44 (20) 7951-6323
Mobile: +44 7738-020-290 Email: tgoodman@uk.ey.com
Stephen Hales +44 (20) 7951-1907
Mobile: +44 7810-681-952 Email: shales1@uk.ey.com
Darrin Henderson, +44 (20) 7951-2423
Financial Services
Mobile: +44 7790-779-553 Email: dhenderson@uk.ey.com
Gareth Lazell +44 (20) 7951-2669 Email: glazell@uk.ey.com
Suwin Lee +44 (20) 7951-7952
Mobile: +44 7770-227-044 Email: slee1@uk.ey.com
Craig Leslie +44 (20) 7951-1121
Mobile: +44 7793-115-244 Email: cleslie@uk.ey.com
Will Lyttle +44 (20) 7951-5341 Email: wlyttle@uk.ey.com
Caspar Noble +44 (20) 7951-1620
Mobile: +44 7717-440-791 Email: cnoble@uk.ey.com
Chris Prout +44 (20) 7951-5969
Mobile: +44 7920-212-998 Email cprout@uk.ey.com
Mark Treherne +44 (20) 7951-5216 Mobile: +44 7748-333-747 Email: mtreherne@uk.ey.com
Chantal Van Stipriaan +44 (20) 7951-6087 Email: cvanstipriaan@uk.ey.com
Bridget Walsh +44 (20) 7951-4176
Mobile: +44 7748-106-165 Email: bwalsh@uk.ey.com
Paul Warn +44 (20) 7951-2185 Mobile: +44 7917-271-045 Email: pwarn@uk.ey.com
Cliff White
+44 (20) 7951-6910
Mobile: +44 7795-427-146 Email: cwhite1@uk.ey.com
Stuart Wilkinson +44 (1223) 394-581 (resident in Cambridge)
Mobile: +44 7469-033-267 Email: swilkinson@uk.ey.com
International Tax and Transaction Services – Global Tax Desk Network
Amit Jain, Head of +44 (20) 7783-0249 Global Tax Desk Network,
Mobile: +44 7393-758-992 EMEIA, and India Desk Email: amit.b.jain1@uk.ey.com
Noor Blauw, Netherlands
+44 (20) 7197-0951
Mobile: +44 7385-344-888 Email: noor.blauw.uk.ey.com
Domenico Borzumato, Italy +44 (20) 7951-5693 Mobile: +39 335-144-4978 Email: dborzumato@uk.ey.com
Joel Cooper, +44 (20) 7951-5832
Transfer Pricing Controversy Desk
Silvestre Del Rio, Mexico
Mobile: +44 7743-123-377 Email: joel.cooper@uk.ey.com
+44 (20) 7197-5024
Mobile: +44 7385-345-273 Email: silvestre.del.rio@uk.ey.com
Derek Drayer, United States +44 (20) 7951-2000 Transfer Pricing and Operating Model Effectiveness (beginning August 2022)
Leif Jorgensen, United States
+44 (20) 7951-1445
Mobile: +44 7825-257-232 Email: ljorgensen@uk.ey.com
Michael Kent, United States +44 (20) 7951-9786
Transaction Tax Mobile: +44 7385-345-155 Email: michael.kent2@uk.ey.com
Satoki Kobayashi, Japan +44 (20) 7951-2000 (beginning August 2022)
David Lanza, United States +44 (20) 7951-2360
Mobile: +44 7707-965-938 Email: david.lanza1@uk.ey.com
Cyril Lau, China Mainland
+44 (20) 7197-7387
Mobile: +44 7387-139-490 Email: cyril.lau@uk.ey.com
Claudia Leon Campos, Colombia +44 (20) 7980-9233
Mobile: +44 7392-106-768 Email: claudia.v.leon.campos1@uk.ey.com
Noah Lewis, +44 (20) 3523-4346 Head of United States Desk Email: noah.lewis1@uk.ey.com
Lourdes Libreros, Mexico
+44 (20) 7197-5101 Mobile: +44 7771-340-071 Email: lourdes.libreros@uk.ey.com
John Michalowski, United States +44 (20) 7951-2000 Transaction Tax (beginning August 2022)
Kwasi Owiredu, Africa
+44 (20) 7951-4942
Mobile: +44 7385-345-171 Email: kwasi.owiredu@uk.ey.com
David Padykula, +44 (20) 7951-1864 United States Email: david.padykula@uk.ey.com
Naomi Ross, Australia +44 (20) 7951-1824
Mobile: +44 7876-877-077 Email: naomi.ross@uk.ey.com
Amit Sachdeva, United States +44 (20) 7951-7071 Transaction Tax Mobile +44 7385-345-242 Email: amit.sachdeva4@uk.ey.com
Hannah Shepley, +44 (20) 7951-4729 United States Email: hannah.shepley2@ey.com Erwin Sieders, Netherlands +31 (88) 407-1468 Mobile: +31 (6) 29-08-43-65 (the above Dutch telephone numbers may be used to reach Erwin Sieders in London) Email: erwin.sieders@nl.ey.com
Gabriel Soto, United States +44 (20) 7951-7214 State and Local Taxes
Mobile: +44 7385-519-157 Email: gabriel.soto2@uk.ey.com
Jillian Symes, United States
Private Client Services
+44 (20) 7951-7863
Mobile: +44 7717-782-501
Email: jsymes@uk.ey.com
Scott Thompson, United States +44 (20) 7951-7140
Tax Accounting and Risk Mobile: +44 7469-036-475 Advisory Services
Email: scott.thompson2@uk.ey.com
International Tax and Transaction Services – Operating Model Effectiveness and Transfer Pricing
Darren Andrews, Financial Services
Simon Atherton
+44 (20) 7951-3976
Mobile: +44 7795-427-466
Email: darren.andrews@uk.ey.com
+44 (20) 7951-4892
Mobile: +44 7768-177-682
Email: satherton1@uk.ey.com
Amar Atwal, +44 (20) 7951-4862
Financial Services
Steven Cawdron
Mobile: +44 7956-527-397
Email: aatwal@uk.ey.com
+44 (20) 7951-4391
Mobile: +44 7717-301-321
Email: scawdron@uk.ey.com
Henrik Hansen, +44 (20) 7951-5939
Financial Services
Mobile: +44 7796-302-466
Email: henrik.hansen3@uk.ey.com
Peter Hartnell, +44 (20) 7951-2763
Financial Services Email: peter.hartnell@uk.ey.com
Eriko Hirai +44 (20) 7951-2297
Mobile: +44 7771-555-278 Email: ehirai@uk.ey.com
David Jones +44 (20) 7951-5326 Email: djones1@uk.ey.com
Tarunya Kumar
+44 (20) 7951-1042
Email: tkumar@uk.ey.com
Ellis Lambert +44 (20) 7951-0632 Mobile: +44 7917-183-600 Email: elambert@uk.ey.com
Andy Martyn, EMEIA Financial Services +44 (20) 7951-9539 Transfer Pricing Leader Email: amartyn@uk.ey.com
Jo Myers +44 (20) 7951-1127 Mobile: +44 7789-948-706 Email: jmyers@uk.ey.com
Martin Powell, +44 (20) 7760-9339 Financial Services
Email: mpowell@uk.ey.com
Ben Regan +44 (20) 7951-4584 Email: bregan@uk.ey.com
Martin Rybak +44 (20) 7951-2539
Kevin Smith
Email: mrybak@uk.ey.com
+44 (20) 7022-9257
Email: kevin.smith@uk.ey.com
Henry Syrett +44 (20) 7951-9172
Mobile: +44 7971-606-587
Email: henry.syrett1@uk.ey.com
Business Tax Services
Robin Aitchison,
+44 (20) 7951-1083 Financial Services
Mobile: +44 7867-550-081
Email: raitchison@uk.ey.com
Charles Brayne, Digital Tax Leader +44 (20) 7951-6337 for United Kingdom and Ireland Email: cbrayne@uk.ey.com
Frank Buffone, +44 (20) 7951-1991 Research and Development
Mobile: +44 7810-843-313
Email: fbuffone@uk.ey.com
Stuart Chalcraft,
Financial Services
+44 (20) 7951-1190
Mobile: +44 7747-475-773 Email: schalcraft@uk.ey.com
Ruth Donaldson +44 (20) 7951-8161 Mobile: +44 7887-628-776 Email: rdonaldson@uk.ey.com
Paul Gallagher +44 (131) 777-2822 Email: pgallagher@uk.ey.com
James Guthrie, +44 (20) 7951-4366 Financial Services Email: jguthrie@uk.ey.com
Anne Hamilton, +44 (20) 7951-1937
Financial Services Mobile: +44 7467-441-979 Email: ahamilton2@uk.ey.com
George Hardy, +44 (20) 7951-0124
Financial Services Mobile: +44 7769-935-830 Email: ghardy@uk.ey.com
Stephen Heath, Capital Allowances +44 (20) 7951-0035 Mobile: +44 7747-454-958 Email: smheath@uk.ey.com
Stephanie Lamb, +44 (20) 7951-1700
Financial Services Mobile: +44 7917-235-371 Email: slamb@uk.ey.com
Joseph Litten +44 (20) 7951-8225 Email: jlitten@uk.ey.com
Roxane Markarian, Incentives +44 (20) 7951-2588 Email: rmarkarian@uk.ey.com
Chris Sanger, +44 (20) 7951-0150 Global Government and Risk Mobile: +44 7956-105-723 Tax Leader Email: csanger@uk.ey.com Joanna Santinon +44 (20) 7951-5510 Email: jsantinon@uk.ey.com
Katie Selvey-Clinton, +44 (20) 7951 3723
Capital Allowances Mobile: +44 7831-136-313 Email: kselvey-clinton@uk.ey.com
Julian Skingley, +44 (20) 7951-7911 Financial Services Mobile: +44 7785-996-764 Email: jskingley@uk.ey.com
Amy Underwood
+44 (20) 7951-3585 Email: aunderwood@uk.ey.com
James Wilson, +44 (20) 7951-5912 Business Tax Services Mobile: +44 7932-644-086 and Tax Controversy and Email: jwilson8@uk.ey.com Risk Management Leader for UKI
Jan Karel Weststrate, +44 (20) 7951-4713 Financial Services Email: jkweststrate@uk.ey.com
Japanese Business Services
Richard Johnston
Mobile: +81 (90) 6170-2472 (resident in Tokyo) Email: richard.johnston@jp.ey.com
Masayuki Owaki +44 (20) 7980-9097 Mobile: +44 7552-271-425 Email: mowaki@uk.ey.com
Global Compliance and Reporting
Julie Hadfield
+44 (20) 7951-0338 Email: jhadfield@uk.ey.com
Kevin Honey +44 (20) 7951-3606 Mobile: +44 7771-703-353 Email: khoney@uk.ey.com Mandy Love, UK&I GCR Leader +44 (20) 7951-0750 Email: mlove1@uk.ey.com
Ben Smith, Global Compliance +44 (20) 7951-8144 and Reporting Leader for Email: bsmith5@uk.ey.com Financial Services for EMEIA
International Trade
Marc Bunch, UK Global
+44 (20) 7980-0298 Trade Leader Email: mbunch@uk.ey.com
Sally Jones, UK Trade Policy +44 (20) 7951-7728 Leader Email: sally.jones@uk.ey.com
Indirect Tax
Andrew Bailey, Indirect Tax Leader
+44 (20) 7951-8565 for Financial Services for EMEIA Mobile: +44 7879-672-874 Email: abailey1@uk.ey.com
Kevin MacAuley, +44 (20) 7951-5728 Indirect Tax Leader for EMEIA Mobile: +44 7887-822-090 Email: kmacauley@uk.ey.com
Jamie Ratcliffe, Head of Indirect +44 (121) 535-2255 Tax, UKI Email: jratcliffe@uk.ey.com
People Advisory Services
Gilly Bryant, Head of People
+44 (20) 7951-0092 Advisory Services, UKI Mobile: +44 7876-791-558 Email: gbryant1@uk.ey.com
Angela Dawes, +44 (20) 7951-2760 Head of People Advisory Services, Mobile: +44 7956-364-147 EMEIA Financial Services Email: adawes@uk.ey.com
Mark Fitzgerald, Head of People +44 (20) 7951-8078 Advisory Services, Mobile: +44 7899-076-212 UK Financial Services Email: mfitzgerald@uk.ey.com
Law
Philip Goodstone, +44 (20) 7951-7995 Head of Law for UKI Email: pgoodstone@uk.ey.com
Sarah Holmes, Head of +44 (20) 7197-9312 Corporate Restructuring Law Email: sholmes3@uk.ey.com
Matthew Kellett, Head of Law +44 (20) 7951-8095 for Financial Services Email: mkellett@uk.ey.com
Richard Thomas, Mergers & Acquisitions +44 (161) 234-0519 Email: rthomas6@uk.ey.com
Aberdeen, Scotland GMT
Ernst & Young LLP
+44 (1224) 653-000 Blenheim House Fax: +44 (1224) 653-001 Fountainhall Road Aberdeen AB15 4DT Scotland
Principal Tax Contacts
Moray Barber, +44 (1224) 653-187 Oil and Gas Email: moray.barber@uk.ey.com
Bob Cardno, +44 (1224) 653-248 Oil and Gas Email: rcardno@uk.ey.com
Shannon Dowdles, +44 (1224) 653-077 Energy Email: sdowdles@uk.ey.com
Derek Leith, +44 (1224) 653-246 Oil and Gas Mobile: +44 7795-402-400 Email: dleith@uk.ey.com
Belfast, Northern Ireland GMT
Ernst & Young LLP
+44 (2890) 443-500 Bedford House Fax: +44 (2890) 443-501 16 Bedford Street Belfast BT2 7DT Northern Ireland
Principal Tax Contact
Rob Heron
+44 (2890) 443-558
Mobile: +44 7884-231-662 Email: rheron@uk.ey.com
Birmingham GMT
Ernst & Young LLP
+44 (121) 535-2000 No. 1 Colmore Square Fax: +44 (121) 535-2001 Birmingham B4 6HQ England
Principal Tax Contacts
Alex Christoforou
Mark Minihane
+44 (121) 535-2922 Email: achristoforou@uk.ey.com
+44 (121) 535-2342
Mobile: +44 7811-372-514 Email: mminihane@uk.ey.com
Amit Thaker, +44 (20) 7951-0714 Financial Services
Mobile: +44 7909-532-489 Email: athaker@uk.ey.com
Steven Wasley +44 (121) 535-2227
Mobile: +44 7810-853-183 Email: swasley@uk.ey.com
Bristol GMT
Ernst & Young LLP
+44 (117) 981-2050
The Paragon Fax: +44 (117) 981-2051 Counterslip Bristol BS1 6BX England
Principal Tax Contact
Karen Kirkwood
+44 (117) 981-2573
Mobile: +44 7740-894-499 Email: kkirkwood@uk.ey.com
Cambridge GMT
Ernst & Young LLP
+44 (1223) 394-400
One Cambridge Business Park Fax: +44 (1223) 394-401 Cowley Road Cambridge CB4 0WZ England
Principal Tax Contact
Stuart Wilkinson
+44 (1223) 394-581
Mobile: +44 7469-033-267 Email: swilkinson@uk.ey.com
Edinburgh, Scotland GMT
Ernst & Young LLP
+44 (131) 777-2000
Fax: +44 (131) 777-2001 Edinburgh EH3 8EB Scotland
Atria One, 114 Morrison Street
Principal Tax Contacts
Peter Ames,
+44 (131) 777-2262 Financial Services Mobile +44 7795-126-726 Email: pames@uk.ey.com
Stewart Mathieson,
Head of Tax, Scotland
+44 (131) 777-2400
Mobile: +44 7748-112-574
Email: smathieson@uk.ey.com
Lynne Sneddon, +44 (131) 777-2339
Business Tax Services Leader, Mobile: +44 7801-639-918
Financial Services, EMEIA
Email: lsneddon@uk.ey.com Ian Wintour
+44 (131) 777-2273
Mobile: +44 7468-745-602 Email: iwintour@uk.ey.com
Glasgow, Scotland GMT
Ernst & Young LLP
+44 (141) 226-9000 G1 Building
Fax: +44 (141) 226-9001 5 George Square Glasgow G2 1DY Scotland
Principal Tax Contacts
Claire Evans +44 (141) 226-9115
Mobile: +44 7715-104-135
Email: cevans2@uk.ey.com
Laura Mair +44 (141) 226-7423
Mobile: +44 7467-441-355 Email: lmair@uk.ey.com
Hull GMT
Ernst & Young LLP
+44 (1482) 590-300 24 Marina Court
Fax: +44 (1482) 590-301 Castle Street Hull HU1 1TJ England
Principal Tax Contact
Tim West
+44 (113) 298-2330 (resident in Leeds)
Mobile: +44 7768-548-733 Email: twest@uk.ey.com
Inverness, Scotland GMT
Ernst & Young LLP
+44 (1463) 667-000 Barony House
Fax: +44 (1463) 667-001 Stoneyfield Business Park Stoneyfield Inverness IV2 7PA Scotland
Principal Tax Contact
Craig Menzies
+44 (141) 226-9303
Email: cmenzies@uk.ey.com
Leeds GMT
Ernst & Young LLP
+44 (113) 298-2200 1 Bridgewater Place
Fax: +44 (113) 298-2201 Water Lane Leeds LS11 5QR England
Principal Tax Contacts
Neil Harrison, +44 (113) 298-2596 Financial Services
Mobile: +44 7789-874-987 Email: nharrison@uk.ey.com
Mark Irving, +44 (113) 298-2217
Financial Services
Robert Peers
Mobile: +44 7799-074-338 Email: mirving@uk.ey.com
+44 (113) 298-2259
Mobile: +44 7827-230-001 Email: rpeers@uk.ey.com
Tim West +44 (113) 298-2330
Mobile: +44 7768-548-733 Email: twest@uk.ey.com
Liverpool GMT
Ernst & Young LLP
+44 (151) 210-4200 20 Chapel Street
Fax: +44 (151) 210-4201 Liverpool L3 9AG England
Principal Tax Contact
Victoria Price
+44 (151) 210-4245
Mobile: +44 7768-558-021 Email: vprice@uk.ey.com
Luton GMT
Ernst & Young LLP +44 (1582) 643-000 400 Capability Green
Fax: +44 (1582) 643-001 Luton LU1 3LU England
Principal Tax Contact
Rob Balchin
+44 (1582) 643-196 Mobile: +44 7771-975-154 Email: rbalchin@uk.ey.com
Manchester GMT
Ernst & Young LLP
+44 (161) 333-3000 100 Barbirolli Square
Fax: +44 (161) 333-3001 Manchester M2 3EY England
Principal Tax Contacts
Sophie Coleman +44 (161) 333-3731 Email: scoleman2@uk.ey.com
Dominic Coupes +44 (161) 333-2813
Mobile: +44 7880-782-905 Email: dcoupes@uk.ey.com
Noam Handler, UKI Leader, +44 (161) 333-2792
Business Tax Services Mobile: +44 7900-004-117 Email: nhandler@uk.ey.com
Martin Portnoy, +44 (161) 333-3275 Private Client Services, Mobile: +44 7770-444-041 Financial Services Email: mportnoy@uk.ey.com
Emma Rayner
+44 (161) 333-2756
Mobile: +44 7920-758-056 Email: emma.rayner@uk.ey.com
Sarah Teshome +44 (161) 333-2905 Mobile: +44 7720-805-597 Email: steshome@uk.ey.com
Graham Wright,
+44 (161) 333-2879
Infrastructure, Power & Utilities Mobile: +44 7789-111-126 Email: gwright1@uk.ey.com
Newcastle-Upon-Tyne GMT
Ernst & Young LLP
+44 (191) 247-2500
Fax: +44 (191) 247-2501 St. James’ Boulevard Newcastle-Upon-Tyne NE1 4JD England
Citygate
Principal Tax Contacts
Richard Clough,
+44 (20) 7951-7601 Financial Services Mobile: +44 7795-506-707 Email: rclough@uk.ey.com
Craig Cumpson
+44 (191) 247-2747 Email: ccumpson@uk.ey.com
Mark Lee, Head of +44 (191) 269-4964
Private Client Services for Mobile: +44 7392-106-682 Financial Services Email: mlee5@uk.ey.com
Reading GMT
Ernst & Young LLP
+44 (118) 928-1100 Apex Plaza
Fax: +44 (118) 928-1101 Forbury Road Reading RG1 1YE England
Principal Tax Contacts
Gareth Anderson +44 (238) 038-2216
Mobile: +44 7867-981-365 Email: ganderson@uk.ey.com
Ian Dennis +44 (118) 928-1278 Mobile: +44 7552-271-569 Email: idennis@uk.ey.com
Anna Fry +44 (118) 928-1428 Mobile: +44 7720-289-053 Email: afry1@uk.ey.com
Caroline Macaskill +44 (118) 921-7884 Email: cmacaskill@uk.ey.com
The United Kingdom left the European Union (EU) on 31 January 2020, although an agreement on transitional arrangements continued until 31 December 2020. During the transition period, the United Kingdom benefited from and was subject to its EU rights and obligations. Following the end of the transition period, the UK is no longer a member of the single market and its relationship with the EU is governed by various agreements, including the Withdrawal Agreement and the Trade and Cooperation Agreement.
A. At a glance
Withholding Tax (%)
Net Operating Losses (Years)
Carryback
1 (h)
Carryforward Unlimited (i)
(a) The rate of corporation tax is 19% for both large and small companies. Legislation has been enacted to increase the rate of corporation tax to 25%, effective from 1 April 2023 for companies with profits of over GBP250,000 per year. From that date, the small profits rate will remain at 19% for compa nies with profits of less than GBP50,000 per year. Companies with profits between the two thresholds will receive marginal relief so that they pay a blended rate between 19% and 25%. The threshold limits are reduced if as sociated companies exist. The main rate of corporation tax for ring-fence profits (that is, profits from oil extraction and oil rights in the United Kingdom and the UK continental shelf) is 30% (small profits rate of 19%). The rates for ring-fence profits are not scheduled to change.
(b) The small profits rate of 19% for ring-fence profits currently applies if tax able profits are below GBP300,000. This benefit is phased out for taxable profits from GBP300,000 to GBP1,500,000. These limits are reduced if as sociated companies exist. However, from 1 April 2023, the relevant thresh olds will be reduced to GBP50,000 and GBP250,000 to match the operation of the small profits rate.
(c) An additional 8% surcharge is levied on the profits of banks in excess of GBP25 million (before the offset of losses carried forward). From 1 April 2023, this surcharge will be reduced to 3%.
(d) From 1 April 2022, residential property developer tax (RPDT) is charged on the trading profits from residential property development activity in addition to standard corporation tax. The rate of RPDT is 4% on residential property development profits that exceed an annual allowance of GBP25 million.
(e) Capital gains are subject to tax at the normal corporation tax rate. See Section B for details concerning the taxation of capital gains derived by nonresidents.
(f) This tax applies to payments to nonresidents and non-corporate residents. (g) A 45% rate applies to compound interest received from the UK tax authorities in certain cases.
(h) Legislation has been enacted to allow for a temporary extension for the car ryback of losses for three years (up to a maximum of GBP2 million), for accounting periods ending between 1 April 2020 and 31 March 2022.
(i) The amount of annual profits that can be relieved by losses carried forward is limited to 50% from 1 April 2017, subject to an allowance of GBP5 million per group.
B. Taxes on corporate income and gains
Corporate income tax. Companies that are resident in the United Kingdom are subject to corporation tax on their worldwide prof its, but several exemptions have the effect of focusing corporation tax on UK-related activities. Tax is imposed on the total amount of income earned from all sources in the company’s accounting period, including any chargeable capital gains. However, a com pany can elect to exempt non-UK branch income and losses from UK corporation tax, subject to transitional rules that govern entry into the regime. This election is irrevocable and takes effect from the accounting period after the one in which the election is made.
Nonresident companies are generally subject to UK corporation tax only if they carry on a trade in the United Kingdom through a permanent establishment (however, companies should also consider any potential diverted profits tax issues; see Section E). A permanent establishment arises either from a fixed place of business in the United Kingdom through which the nonresident
company carries on its business, or from an agent exercising authority to do business in the United Kingdom on behalf of the nonresident company. The amount of profit attributable to a permanent establishment is computed in accordance with the separate enterprise principle. A corporation tax charge is also imposed for nonresidents disposing of UK land in the course of a property dealing or development trade, regardless of whether there is a UK permanent establishment and regardless of the residence of the entity.
From 6 April 2020, non-UK resident companies that carry on a UK property business or have other UK property income are chargeable to corporation tax (rather than income tax) on that income. Relief for financing costs relating to property business is subject to the normal corporation tax rules (including applica tion of the corporate interest restriction).
A company is resident in the United Kingdom if it is incorporated in the United Kingdom or if the central management and control of the company is exercised there. However, companies regarded as resident under domestic law, but as nonresident under the tiebreaker clause of a double tax treaty, are regarded as nonresident for all corporation tax purposes.
Rates of corporation tax. The rate of corporation tax for both large and small companies is 19%. However, the UK government en acted legislation in 2021 providing that the rate of corporation tax will increase to 25%, effective from 1 April 2023 for companies with profits of over GBP250,000 per year. From that date, the small profits rate will remain at 19% for companies with profits of less than GBP50,000 per year. Companies with profits between the two thresholds will receive marginal relief so that they pay a blended rate between 19% and 25%. These limits are divided by one plus the number of associates if a company has associated companies (subsidiaries or fellow subsidiaries), regardless of whether they are in or outside the United Kingdom. If an account ing period does not coincide with the financial year, the profits for the accounting period are time-apportioned and the appropriate rate is applied to each part.
The rate is 30% for companies with ring-fence profits (that is, profits from oil extraction and oil rights in the United Kingdom and the UK continental shelf). For ring-fence profits, a company may claim a small profits rate of corporation tax, which is 19%, if its taxable profits for an accounting period are less than GBP300,000. Ring-fence companies can claim marginal relief on profits between GBP300,000 and GBP1,500,000. These limits are divided by one plus the number of associates if a company has associated companies (subsidiaries or fellow subsidiaries), re gardless of whether they are in or outside the United Kingdom. From 1 April 2023, the relevant thresholds will be aligned with the small profits rate and reduced to GBP50,000 and GBP250,000.
An additional 8% surcharge is levied on the profits of banks in excess of GBP25 million (before the offset of losses carried forward), effective from 1 January 2016. From 1 April 2023, the additional surcharge is reduced to 3%, producing an overall rate on those profits of 28%. RPDT is a tax on the trading profits of residential property developers charged in addition to standard
corporation tax. It applies to profits arising from residential prop erty development activity from 1 April 2022, including a proportion of profits of accounting periods that straddle that date. Companies not liable to corporation tax, or companies that do not carry on a trade within the charge to corporation tax, are outside the scope of the tax. For companies within the scope of the tax, RPDT is charged at 4% on residential property development profits that exceed an annual allowance of GBP25 million.
A special rate of corporation tax of 45% applies on restitution interest, which is compound interest received from the UK tax authorities on the repayment of tax (either by agreement or an order of a court) originally collected in breach of law, which ap plies to awards determined on or after 21 October 2015.
Capital gains. Gains on chargeable assets are subject to corpora tion tax at the corporation tax rate. For UK tax purposes, a capital gain is usually the excess of the sale proceeds over the sum of the original cost and any subsequent qualifying capital expenditure incurred on the chargeable asset being disposed of. If chargeable assets acquired before 31 March 1982 are disposed of, only the portion of the gain after that date is usually taxable. An allowance is available for inflation up to 31 December 2017; the amount of the reduction is based on the increase in the retail price index between the date of acquisition (or 31 March 1982, if later) and 31 December 2017. This indexation allowance may be used only to eliminate a gain; it may not be used to create or increase an allowable loss.
The Substantial Shareholdings Exemption (SSE) broadly exempts from UK tax any chargeable gain on disposals made by trading companies or trading groups with substantial shareholdings (at least 10%) in other trading companies or groups. Broadly, the following are the two sets of conditions that must be satisfied:
• A substantial shareholding requirement
• A trading requirement relating to the “investee” company or subgroup
No tax is levied on a gain on the sale of shares in a UK subsidiary by a foreign nonresident parent company unless that company is deemed to represent a property-rich asset by way of an indirect disposal of property (see below). In addition, gains on the sale of assets situated in, and used in a trade carried on by a permanent establishment in, the United Kingdom are subject to corporation tax at the corporation tax rate.
Special provisions permit the deferral of the capital gains charge on qualifying business assets if the sales proceeds are reinvested. There are numerous other special rules relating to capital gains.
From 6 April 2019, UK tax is chargeable on gains derived by non-UK residents on the direct or indirect disposal of all types (residential or commercial) of UK immovable property. This applies regardless of the nature of the property or the residence of the disposing entity.
The charge also applies to certain disposals by nonresidents of interests (such as shares or partnership interests) that derive their value from UK property.
Capital losses. Capital losses are offset against capital gains of the same accounting period and, if an excess exists, they may be carried forward indefinitely (to be set off against chargeable gains of future accounting periods), but may not be carried back. Capital losses may not be used to reduce trading profits. See Relief for losses in Section C for proposals that restrict the amount of losses that can be used in any one year, which are effective from April 2020.
Administration. Tax returns, accounts and computations must be filed within 12 months after the end of the accounting period.
Large companies (companies with annual taxable profits exceed ing GBP1,500,000 divided by one plus the number of active associated companies) make quarterly installment payments of their corporation tax. The first installment is due 6 months and 13 days after the first day of the accounting period, and the last installment is due 3 months and 14 days after the end of the accounting period. These payments are based on the estimated tax liability for the current year. Fewer payments may be required for shorter accounting periods.
For accounting periods beginning on or after 1 April 2019, the installment payment dates for corporation tax for “very large companies” (annual taxable profits exceeding GBP20 million divided by one plus the number of active associated companies) are brought forward. These companies are required to pay corpo ration tax in quarterly instalments in the 3rd, 6th, 9th and 12th months of their accounting period (rather than in the 7th and 10th months of the current accounting period and the 1st and 4th months of the following accounting period). All other companies must pay estimates of their corporation tax liability within nine months after the end of their accounting period.
Companies not complying with the filing and payment deadlines described above are subject to interest and penalties.
A self-assessment system requires companies to assess correctly their tax liabilities or face significant penalties. In addition, the tax authority (HMRC) has extensive investigative powers.
Large businesses (see definition below) must publish annually their UK tax strategy. Those businesses that fail to do so cor rectly and in time are liable to a penalty. The UK tax strategy report for each accounting period must be published before the end of the accounting period to which it relates (and within 15 months of the previous one being published). The tax strategy report should include the approach of the UK group to tax gov ernance and risk management, as well as its attitude toward tax planning, the level of risk in relation to UK taxation that the group is prepared to accept and its approach to dealing with HMRC. In broad terms, the following entities are required to publish a tax strategy:
• UK subgroups of and subsidiaries and permanent establish ments of multinational groups with EUR750 million global turnover (that is, those that fall within the Country-by-Country Reporting [CbCR] requirement)
• UK-headed groups, some specific UK subgroups and standalone UK entities (including companies and partnerships) with at least either GBP200 million of turnover or a balance sheet total exceeding GBP2 million
A key point is that no de minimis level is set for UK entities that are part of a EUR750 million turnover group. A UK company, subgroup or permanent establishment that is part of such a mul tinational group must publish a strategy, even if the level of activ ity in the UK is minimal.
The UK CBCR rules require large UK-headed multinational en terprises (MNEs) to provide HMRC with information about global activities, profits and taxes. They also require UK entities of foreign-headed MNEs to provide HMRC with information if those results would not otherwise be reported. Groups with turn over greater than EUR750 million are required to submit reports to HMRC within 12 months from the end of the accounting pe riod, and there are also notification requirements. The information provided to HMRC is exchanged with other tax authorities.
From 1 April 2022, there is a requirement for large companies or partnerships to notify HMRC of any uncertain tax treatments (UTT) if there is a “tax advantage” of GBP5 million or more in the relevant period for the relevant tax (which includes corpora tion tax). Notification must be made on or before the filing deadline of a related “relevant return” that is due after 1 April 2022. There is an exemption to this requirement if HMRC is al ready aware of the uncertainty and how the business plans to treat it.
A UTT may arise when one or both of the following two triggers are met:
• The amount relates to a transaction with respect to which a provision has been recognized in the accounts of the qualifying company or partnership, to reflect that a different tax treatment may be applied to the transaction.
• In arriving at the amount, reliance was placed on an interpreta tion or application of the law that is different to HMRC’s known interpretation or application
The UTT only applies to large businesses with a UK turnover above GBP200 million and/or a UK balance sheet total more than GBP2 billion. It applies to partnerships and limited liability part nerships (wherever formed, incorporated, or managed and con trolled) that satisfy these criteria, as well as corporates (wherever incorporated or tax resident).
Inward Investment Support. Significant inward investors can apply under HMRC’s Inward Investment Support service for written confirmation of the UK tax treatment of specific transac tions or events. In this context, “significant” is regarded as an investment of GBP30 million or more, but smaller investments are considered if they are potentially of importance to the na tional or regional economy.
Dividends. Dividends paid by UK resident companies are not sub ject to withholding tax. For dividends received by UK resident
companies, the United Kingdom has a dividend exemption re gime. A dividend or other income distribution received on or after 1 July 2009 is generally exempt from UK corporation tax if all of the following conditions are satisfied:
• The distribution falls within an exempt class or, if the recipient is a “small” company, the payer is resident in the United Kingdom or a qualifying territory.
• The distribution is not of a specified kind.
• No deduction is allowed to a resident of any territory outside the United Kingdom under the law of that territory with respect to the distribution.
Interest. Interest payments on “short loans” (loans with a duration that cannot exceed 364 days) may be made without the need to account for withholding tax. All interest payments by UK resident companies may be made without the imposition of withholding tax if the paying company reasonably believes that the interest is subject to UK corporation tax in the hands of the recipient. See Section E for a summary of the UK’s rules on tax deductions for interest payments.
Foreign tax relief. Foreign direct tax on income and gains of a UK resident company other than that relating to a non-UK branch for which an exemption election has been made (see Corporate in come tax) may be credited against the corporation tax on the same profits. The foreign tax relief cannot exceed the UK corporation tax charged on the same profits.
If a company receives a dividend from a foreign company in which it has at least 10% of the voting power, it may also obtain relief for the underlying foreign tax on the profits out of which the dividend is paid. Foreign tax relief does not apply if the divi dend satisfies the conditions for the dividend exemption, unless an election is made (see Dividends).
C. Determination of trading income
General. The assessment is based on financial statements pre pared in accordance with generally accepted accounting princi ples (GAAP), subject to certain adjustments and provisions. Since 1 January 2015, most UK entities (with limited exceptions) have been required to report either under International Financial Reporting Standards or under Financial Reporting Standards in the United Kingdom and Republic of Ireland (either FRS 101 or 102).
In general, to be deductible, expenses must be incurred wholly and exclusively for the purposes of the trade. However, specific reliefs and prohibitions exist for certain expenses. For example, no deduction is allowed for entertainment expenses, except for the entertaining of company employees (in certain circumstanc es).
Corporate and government debt and foreign-exchange differences. The rules under the “loan relationships” regime are designed to allow the tax treatment of interest, discounts and premiums on debt instruments to follow the accounting treatment in most circumstances. However, the regime includes many anti-abuse mea sures as well as other measures, which can restrict the allowable deductions (for further details, see Section E).
Foreign-exchange differences on most items are taxable or reliev able when they are recognized in the profit-and-loss account. Specific rules apply to foreign-exchange differences arising on loans that hedge exchange risk on shareholdings.
Inventory. Inventory is normally valued at the lower of cost or net realizable value. Cost must be determined on a first-in, first-out basis; the last-in, first-out basis is not acceptable for tax purpos es, even if permitted under GAAP.
Provisions. HMRC allows specific provisions made in accordance with GAAP to be deductible for tax purposes unless specific leg islation provides to the contrary. However, no expenditure may be relieved more than once.
Leased assets. If leases of plant or machinery function essen tially as financing transactions (long-funding leases), they are taxed as such and the following rules apply:
• The lessor includes only the finance element of the rentals aris ing under the lease income.
• The lessee deducts only the finance element of the rentals pay able over the life of the lease and is entitled to capital allowances.
This regime applies to finance leases and certain operating leases. With the exception of some hire-purchase transactions, leases of less than five years are not affected.
The UK government has amended the legislation relating to the taxation of leases to ensure that it continues to work as set out above following the introduction of International Financial Reporting Standard (IFRS) 16. However, accounting adjustments may arise in lessee companies on adoption of IFRS 16; the tax treatment of these adjustments is complex, but they will typically be taxable or deductible for tax purposes, spread over the remain ing lease term.
Tax depreciation (capital allowances)
Capital allowances are usually subject to recapture on the dis posal of an asset on which capital allowances have been claimed.
Plant and machinery. Expenditure on plant and machinery bought after April 2009 is pooled together (the main pool), and allowances are given at 18% on a reducing-balance basis. Assets with a useful life of 25 years or more (long-life assets) are depreciated at 8% on a reducing-balance basis (this rate falls to 6% per year from 1 April 2019). Integral features to a building also qualify for the 8% rate of capital allowances (this rate also falls to 6% from 1 April 2019). An annual investment allowance (AIA) of 100% is available and applies to the first GBP200,000 of investment in plant and machinery (other than cars) by all businesses, regardless of size. One AIA is available to each individual business or corporate group.
As a result of an extension of the temporary increase in the AIA from GBP200,000 to GBP1 million, the increased figure applies for expenditure incurred between 1 January 2019 and 31 March 2023. Also, two new first-year allowances for companies have been enacted. They are a super-deduction of 130% for main pool expenditure, and a first-year allowance of 50% for special rate expenditure (including long-life assets). These new allowances
are effective for expenditure incurred from 1 April 2021 up to and including 31 March 2023, but specifically exclude expenditure incurred as a result of a contract entered into prior to 3 March 2021. The qualifying expenditure is subject to several exclusions, including a general exclusion on cars, second-hand assets and assets held for leasing.
Cars. The capital allowances rules for cars are based on their CO2 emissions per kilometer driven. For expenditure on new cars incurred before 31 March 2021, a 100% first-year allowance rate applies for electric cars and cars with CO2 emissions of 50g/km or less. Cars emitting between 50g/km and 110g/km are added to the main pool, and the 18% rate applies. Cars emitting above 110g/km are added to the special-rate pool, and the 8% rate applies. From 1 April 2021, the first-year allowance is available only for new cars that are either electric cars or have CO2 emis sions of 0g/km. Cars emitting between 0g/km and 50g/km are added to the main pool while cars emitting above 50g/km are added to the special-rate pool. For leased cars with CO2 emis sions above 110g/km (50g/km for cars bought after 1 April 2021), 15% of the lease cost is disallowed for tax purposes. The 100% first-year allowance rate does not apply to cars that will be leased.
Nonresidential structures and buildings. A Structures and Buildings Allowance applies for new nonresidential buildings and structures (excluding land) at an annual rate of 3% on a straight-line basis (previously 2% up to March 2020). The allow ance applies to contracts for construction works entered into on or after 29 October 2018.
Other. Capital allowances are also available for certain other types of expenditure, such as expenditure on mineral extraction and dredging.
Relief for losses
Trading Losses. Trading losses may be used to relieve other income and capital gains of the year in which the loss was incurred and of the preceding year, provided the same trade was then car ried on. Losses incurred prior to 1 April 2017 may also be carried forward without time limit but may only be relieved against fu ture profits from the same trade. The use of losses that are carried forward as at 31 March 2015 by banks was restricted from that date to an offset of a maximum of 50% of profits and further restricted from 31 March 2016 to 25%. Anti-avoidance provi sions exist to prevent the offset of losses carried forward in ar rangements that are principally tax driven. A company that ceases trading may carry back trading losses and offset them against profits of the preceding 36 months.
For trade losses of the 2020-21 and 2021-22 tax years, unrelieved losses can be carried back and offset against profits of the same trade for three years before the tax year of the loss.
The amount of trading losses that can be carried back to the pre ceding year remains unlimited for companies. After carrying back losses to the preceding year, a maximum of GBP2 million of unused losses will be available for carryback against profits of the same trade to the earlier two years. This means a cap of on the
extended carryback of losses incurred in accounting periods end ing in the period of 1 April 2020 to 31 March 2021 and a separate cap of GBP2 million on the extended carryback of losses in curred in accounting periods ending in the period of 1 April 2021 to 31 March 2022.
Non-trading losses. Relief is also available for non-trading deficits and management expenses. Specific rules provide how such losses can be used or carried forward and the order in which they can be used.
Rules relating to use of carried-forward corporate tax losses in periods beginning on or after 1 April 2017. New legislation on corporation tax loss relief was introduced with effect for account ing periods beginning on or after 1 April 2017 (accounting peri ods straddling 1 April 2017 being deemed to be split into two for this purpose).
The rules increase groups’ flexibility to use carried-forward losses, but restrict the amount of losses that can be used in any one year. They provide the following:
• Losses arising in accounting periods beginning on or after 1 April 2017 can be carried forward and offset against total profits of the company and group, rather than being restricted to particular types of income. However, losses arising prior to 1 April 2017 remain subject to existing restrictions as to the profits against which they can be offset.
• The amount of annual profit incurred in accounting periods beginning on or after 1 April 2017 that can be relieved by brought forward losses (whether arising before or after 1 April 2017) is limited to 50% from 1 April 2017, subject to a GBP5 million allowance per “group” (“group” for this purpose is determined using concepts similar to those in the definition found in the group relief rules but with key differences). Groups have full discretion as to how the GBP5 million allow ance is used within the group. This allowance also applies to the carryforward of capital losses (see below).
No new restrictions are imposed on the carryback of losses, and groups have full discretion as to how the GBP5 million allowance is used within the group.
Losses for the purposes of the new rules mean trading losses, non-trading loan relationship deficits, UK property losses, man agement expenses and non-trading losses on intangible fixed assets.
Capital losses. For disposals occurring on or after 1 April 2020, companies’ ability to obtain relief for capital losses carried for ward in each period is restricted to 50% of net capital gains aris ing in that period. Groups have a single allowance that allows groups unrestricted use of up to GBP5 million capital or income losses each year.
Groups of companies. UK law does not provide for tax consolida tion. However, a trading loss incurred by one company within a 75%-owned group of companies may be grouped with profits for the same period realized by another member of the group. Similar provisions apply in certain consortium situations to allow a transfer of a proportion of the losses; for this purpose, a UK
resident company is owned by a consortium if 75% or more of its ordinary share capital is owned by other companies, none of which individually has a holding of less than 5%. However, the consortium-owned company must not be a 75%-owned subsid iary of any company. In both situations, anti-avoidance provi sions that aim to prevent artificial arrangements exist.
Capital losses cannot be grouped with capital gains of other group members under the above provisions. However, the seller of an asset and another group company may jointly elect to transfer a capital gain or allowable loss to enable offset of capital gains and capital losses. A transferred capital loss can be carried forward in the transferee company.
In a capital gains worldwide group (a 75% group but with some differences from the 75% group for group relief purposes), the transfer of assets between group companies does not result in a capital gain if the companies involved are subject to UK corpora tion tax. The transferee company assumes the transferor’s original cost of the asset plus subsequent qualifying expenditure and in dexation. However, under an anti-avoidance provision, if the transferee company leaves the group within six years after the date of the transfer of the asset, that company is deemed to have dis posed of and reacquired the asset at its market value immediately after the transfer. In certain circumstances, the chargeable gain or allowable loss that arises is added to or deducted from the proceeds of a share sale that caused the company to leave the group in the first place. The resulting gain or loss can then potentially be exempted or disallowed under the SSE (see Capital gains). If this provision does not apply, the gain or loss remains in the com pany that has left the group, but the gain or loss can be transferred by election to another company in the group. Anti-avoidance provisions that aim to prevent artificial arrangements exist. Specific rules apply to certain transfers of assets to EU group companies outside the UK corporation tax net that allows the tax due to be paid in six equal installments. The rules apply to gains arising in accounting periods ending on or after 10 October 2018 and are still in place after the end of the Brexit transition period.
Similar provisions for tax-neutral transfers between members of the same capital gains worldwide group with respect to assets subject to the intangible fixed assets regime exist. If the trans feree company leaves the group within six years of the date of the transfer of the asset, then de-grouping occurs and the company is deemed to dispose and reacquire the asset at its market value at the time of the transfer and must make appropriate adjustments in its return. For de-groupings on or after 7 November 2018, a degrouping does not arise in situations in which a company leaves a group as a result of a share disposal that qualifies for the SSE (see Capital gains), subject to anti-avoidance provisions.
Companies in the same capital gains worldwide group may also transfer debt assets and liabilities (which are loan relationships) and derivative contracts on a tax-neutral basis. However, if a degrouping event occurs as the transferee leaves the group within six years, the transferee is deemed to have disposed of the asset or liability for consideration equal to the fair value of the asset or liability at the time of leaving the group. Unlike capital gains
assets and intangible fixed assets, no reliefs are available to miti gate any de-grouping credit (gain) or debit (loss) that arises in the transferor company.
D. Other significant taxes
The following table summarizes other significant taxes.
Nature of tax Rate
Value-added tax (VAT); on any supply of goods or services, other than an exempt supply, made in the United Kingdom by a taxable person in the course of business (for businesses established in the United Kingdom only); taxable if annual supplies exceed GBP85,000 0%/5%/20% (Temporary reduced rates of VAT apply to certain supplies relating to hospitality, hotel and holiday accommodation and to admissions to certain attractions in the period 15 July 2020 to 31 March 2022.)
Digital services tax (DST); charged on gross revenues earned from 1 April 2020 by search engines, social media services and online marketplaces that derive value from UK users; a group is liable to DST if the worldwide revenues attributable to such activities exceed GBP500 million and more than GBP25 million of these revenues are attributable to UK users; a group’s first GBP25 million of revenues derived from UK users is not subject to DST; an exclusion applies to online financial marketplaces 2% Stamp duty; imposed on transfers of shares, securities and interests in certain partnerships; duty charged on the stampable consideration 0.5% Stamp duty land tax (SDLT); imposed on transfers of land and buildings and certain partnership transactions; tax is charged on the final consideration, but this may be replaced by market value in certain circumstances (not applicable in Scotland and Wales; see Land and Buildings Transaction Tax [LBTT] in Scotland and Land Transaction Tax [LTT] in Wales below)
Acquisitions of residential property by companies and certain other bodies (SDLT is charged at increasing rates for each portion of the price paid, but no SDLT is due if the consideration is less than GBP40,000); rates applicable from 1 October 2021
Portion up to GBP125,000 3%
Portion between GBP125,001 and GBP250,000 5%
Portion between GBP250,001 and GBP500,000 5%
Consideration exceeds GBP500,000; SDLT is charged on the total consideration (subject to certain exclusions) 15%
Nature of tax Rate
(There is also a 2% surcharge on residential properties in England and Northern Ireland bought by non-UK residents on or after 1 April 2021.)
Nonresidential or mixed-use property
Up to GBP150,000 0%
GBP150,001 to GBP250,000 2%
More than GBP250,000 5%
LBTT
Acquisitions of residential property by companies and certain other bodies (LBTT is charged at increasing rates for each portion of the price paid, but no LBTT is due if the consideration is less than GBP40,000); rates applicable from 1 April 2021
Portion up to GBP145,000 4%
Portion between GBP145,001 and GBP250,000 6%
Portion between GBP250,001 and GBP325,000 9%
Portion between GBP325,001 and GBP750,000 14%
Portion above GBP750,000 16%
Nonresidential or mixed-use property
Portion up to GBP150,000 0%
Portion between GBP150,001 to GBP250,000 1%
Portion above GBP250,000 5%
LTT
Acquisitions of residential property by companies and certain other bodies (LTT is charged at increasing rates for each portion of the price paid, but no LTT is due if the consideration is less than GBP40,000) rates applicable from 22 December 2020
Portion up to GBP180,000 4%
Portion between GBP180,001 and GBP250,000 7.5%
Portion between GBP250,001 and GBP400,000 9% Portion between GBP400,001 and GBP750,000 11.5% Portion between GBP750,001 and GBP1,500,000 14% Portion above GBP1,500,000 16%
Nonresidential or mixed-use property
Portion up to GBP225,000 0%
Portion between GBP225,001 and GBP250,000 1% Portion between GBP250,001 and GBP1,000,000 5% Portion above GBP1,000,000 6%
Social security contributions, on employees’ salaries and wages (rates in brackets apply from 6 April 2022); payable on weekly wages by Employer; imposed on employees’ weekly wages exceeding GBP170 (GBP175 from 6 April 2022) 13.8% (15.05%) Employee; imposed on employees’ weekly wages
On first GBP184 (GBP190 from 6 April 2022; GBP 242 from 6 July 2022) 0% (0%)
On next GBP783 (GBP777 from 6 April 2022; GBP 725 from 6 July 2022) 12% (13.25%)
On balance of weekly wage 2% (3.25%)
Nature of tax Rate
Bank levy; based on the total chargeable equity and liabilities (subject to various exclusions) as reported in relevant balance sheets at the end of a chargeable period; a half-rate applies to long-term amounts and a nil rate allowance is granted for the first GBP20 billion (2022 rates)
0.1%/0.05% Annual Tax on Enveloped Dwellings (ATED); a UK-wide levy on certain higher value residential property held by companies and partnerships with a corporate member; several reliefs are available to exempt genuine property development and investment rental businesses from the tax; the tax is levied at a flat rate per year; the rates in brackets apply from April 2022
Properties worth between GBP500,000 and GBP1 million
Properties worth more than GBP1 million and not more than GBP2 million
Properties worth more than GBP2 million and not more than GBP5 million
GBP3,700 (GBP3,800)
GBP7,500 (GBP7,700)
GBP25,200 (GBP26,050)
Properties worth more than GBP5 million and not more than GBP10 million GBP58,850 (GBP60,900)
Properties worth more than GBP10 million and not more than GBP20 million
GBP118,050 (GBP122,250)
Properties worth more than GBP20 million GBP236,250 (GBP244,750)
E. Miscellaneous matters
Foreign-exchange controls. No restrictions are imposed on inward or outward investments. The transfer of profits and dividends, loan principal and interest, royalties and fees is unlimited. Nonresidents may repatriate capital, together with any accrued capital gains or retained earnings, at any time, subject to com pany law or tax considerations.
Anti-avoidance legislation. UK tax law contains many anti-avoidance provisions, which include the substitution of an arm’s-length price for intercompany transactions (including intercompany debt) with UK or foreign affiliates, the levy of an exit charge on companies transferring a trade or their tax residence from the United Kingdom and the recharacterization of income for certain transactions in securities and real property. Some of these anti-avoidance provisions apply only if the transaction is not carried out for bona fide commercial reasons.
In certain situations, legislation provides a facility for an advance clearance to be obtained from HMRC. If legislation does not pro vide this facility and if uncertainty exists as to the tax treatment for a transaction, a non-statutory clearance facility exists under which companies may apply to HMRC in advance of the transac tion for a written confirmation of HMRC’s view on how the tax
law will apply to the transaction. HMRC undertakes to provide advance clearance within 28 days if evidence exists that the transaction is genuinely contemplated. It also aims to respond within this time period if certainty is sought for a transaction that has already taken place. HMRC does not provide clearance if it be lieves that the arrangements are primarily intended to obtain a tax advantage.
The United Kingdom has implemented a system requiring the disclosure of certain transactions and arrangements to HMRC. As a direct result of this disclosure regime, tax-planning arrange ments are sometimes disclosed in advance to HMRC.
Although the United Kingdom had enacted legislation to imple ment the EU directive on mandatory disclosure (the Mandatory Disclosure Regime [MDR]) and automatic exchange of informa tion regarding reportable cross-border arrangements from 1 July 2020, the UK’s position subsequently changed following the conclusion of the Trade and Cooperation Agreement with the EU, which was reached in December 2020. Only those arrangements that meet the Category D hallmark of EU Directive 2018/822 (DAC 6) will need to be reported in the United Kingdom. This applies to arrangements entered into between 25 June 2018 and 31 December 2020 and new arrangements entered into from 1 January 2021. The UK government is still in consultation on draft regulations to implement the Mandatory Disclosure Rules of the Organisation for Economic Co-operation and Development (OECD) to replace the current rules.
A general anti-abuse rule (GAAR) has been in force since 2013. The GAAR targets artificial and abusive tax-avoidance schemes and applies to the main taxes but not VAT.
Anti-hybrid rules. The previous rules counteracting structures in volving hybrid entities or instruments (the anti-arbitrage rules) were replaced with broader anti-hybrid rules from 1 January 2017 in response to Action 2 of the Base Erosion and Profit Shifting (BEPS) project of the OECD. The rules effectively target deduc tion or non-inclusion or double deduction mismatches resulting from hybrid entities or instruments, dual-resident companies or companies with permanent establishments. The rules also cover imported mismatches. This is a situation in which the UK corpo rate taxpayer is not directly party to a relevant mismatch, but such a mismatch exists within a wider arrangement. Unlike the previ ous anti-arbitrage rules, the new rules do not contain a purpose test, and it is only necessary for it to be reasonable to suppose that the mismatch arises as a result of the specified features.
In deduction or non-inclusion cases, the mismatches are coun tered by the following:
• Disallowing a deduction if the payer is within the charge to UK corporation tax
• In cases in which the United Kingdom is the payee jurisdiction, taxing the income if it is reasonable to assume that the deduc tion has not been counteracted by equivalent rules outside the United Kingdom
In cases in which a double deduction is in more than one terri tory, the outcome depends on the structure and whether the other
territory takes action. However, the rules often result in the United Kingdom denying a deduction unless the deduction is offset against dual-inclusion income in the same entity. Revisions to the rules, which provide relief in several situations, have been enacted. Some of these revisions have effect from January 2017.
Royalty withholding tax. Rules apply to deny the benefit of double tax treaties if connected-party arrangements have as a main purpose, or one of the main purposes, the avoidance of withholding tax on intellectual property (IP) royalty payments. The rules also treat IP royalty payments paid by a nonresident company in connection with a UK permanent establishment as having a UK source and being subject to withholding tax. If such royalty payments are made in connection with an avoided permanent establishment, a diverted profits tax charge is imposed (see Diverted profits tax).
UK tax treatment of intangible assets. The intangible fixed assets (IFA) regime was introduced in 2002 and changed the way the UK corporation tax system treats IFAs (such as copyrights, pat ents and trademarks) and goodwill by, in general, aligning the tax treatment of assets within the scope of the regime with the accounting treatment. Broadly, the commencement rules to the IFA regime mean that it does not apply to assets that existed at 1 April 2002 unless the assets were acquired from an unrelated party on or after that date. However, the 2020 Finance Act now brings pre-2002 IFAs transferred to the United Kingdom after 1 July 2020 into the scope of the IFA regime (subject to certain restrictions). A change to the regime in 2015 meant that relief for amortization for goodwill and customer-related intangibles was removed. Targeted relief for goodwill and certain other assets was then reinstated from 1 April 2019.
Offshore receipts with respect to intangible property. Legislation imposes a 20% tax on gross receipts that certain foreign compa nies receive with respect to their intangible property if such receipts are referable to the sale of goods or services in the United Kingdom (whether that be directly by the company or indirectly, including through an unrelated party). The legislation includes some exemptions to the tax, as well as an anti-avoidance rule and a formula for apportioning income between the UK and other countries. The measure does not apply to entities that are resident in states with whom the United Kingdom has a “full tax treaty” (that is, a tax treaty that includes a nondiscrimination article), provided that the territory does not tax only on a remittance or local source basis. The legislation generally applies from 6 April 2019, but the anti-avoidance rules apply from 29 October 2018, and some specific amendments apply only from 5 November 2019.
Transfer pricing. UK tax law contains measures that substitute an arm’s-length price for certain intercompany transactions with UK or foreign affiliates. Companies are required to prepare their tax returns in accordance with the arm’s-length principle, and retain adequate records or other documentation to support their compliance with that principle, or otherwise suffer substantial penalties. New transfer-pricing documentation requirements are currently under consultation. The transfer-pricing rules have
other far-reaching consequences, and taxpayers should seek specific advice concerning their circumstances.
If both parties to a transaction are subject to UK corporation tax, and one is required to increase its taxable profits in accordance with the arm’s-length principle, the other is usually allowed to decrease its taxable profits through a corresponding adjustment.
Companies that were dormant as of 31 March 2004 and remain dormant are exempt from the transfer-pricing rules. Although small and medium-sized companies (unless they elect otherwise) are exempt from the rules with respect to transactions with per sons in qualifying territories (broadly, the United Kingdom and those countries with which the United Kingdom has entered into a double tax treaty containing a non-discrimination article), they can be subject to the issuance of a transfer-pricing notice by HMRC. However, for small companies, this notice can be issued only if the company has undertaken a non-arm’s-length transac tion with an affiliate that is taken into account in determining profits under the Patent Box regime (see Patent Box).
Persons that are otherwise independent but collectively control a business and have acted together with respect to the financing arrangements for the business are also subject to the UK transferpricing regime.
Interest restrictions. The United Kingdom’s transfer-pricing mea sures apply to the provision of finance (as well as to trading in come and expenses). As a result, companies must self-assess their tax liability on financing transactions using the arm’s-length principle. Consequently, HMRC may challenge interest deduc tions on the grounds that, based on all of the circumstances, the loan would not have been made at all or that the amount loaned or the interest rate would have been less, if the lender was an unrelated third party acting at arm’s length.
In addition, new rules are in effect for financial periods beginning on or after 1 April 2017 (periods straddling 1 April 2017 being deemed to be split into two for this purpose). Under the new rules, the amount of relief for interest is capped at the lower of 30% of taxable earnings before interest, depreciation and amortization (EBITDA) in the United Kingdom or the modified debt cap (the fixed ratio rule). This is tighter than the previous and now-repealed Worldwide Debt Cap and provides that a group’s net tax-interest amounts in the United Kingdom cannot exceed the global net adjusted interest expense of the group. Alternatively, groups can elect for the restriction to be based on the ratio of net interest (excluding interest paid to related parties) to accounting EBITDA for the worldwide group as opposed to UK taxable EBITDA (the group ratio rule, which is also subject to a modified debt cap). If a group’s net tax-interest expense exceeds its interest capacity, the excess interest is disallowed. However, the excess interest can be carried forward indefinitely (in the company in which it was disallowed) and treated as if it were an amount of interest in a subsequent period. If a group has spare capacity, it can carry this forward for up to five years. Restricted interest or spare capacity cannot be carried back.
Notwithstanding the above rules, groups may always deduct net tax-interest expense of up to GBP2 million per year (subject to existing anti-avoidance and thin-capitalization provisions).
Controlled foreign companies. The controlled foreign company (CFC) regime was significantly revised in 2012, effective for accounting periods beginning on or after 1 January 2013. The regime applies to non-UK resident companies that are controlled by UK residents. Similar rules apply to non-UK branches of UK resident companies for which an exemption election has been made.
The regime is similar to the prior regime in that, if a CFC has profits that do not meet any of the exemptions, those profits are taxed on any UK resident companies having a 25% or more inter est in the CFC. However, the regime is much more focused on identifying artificial diversion of profits out of the United Kingdom. Consequently, it is necessary to examine a company’s income on a source-by-source basis to determine whether it falls within one of the “gateways,” or whether one of the entity exemp tions applies.
The following are the five “gateways,” which must all be considered:
• Profits attributable to UK activities
• Non-trading finance profits
• Trading finance profits
• Captive insurance business
• Solo consolidation (for banking subsidiaries), which allows a UK bank to treat the foreign company as it were a division of the UK bank
For each gateway test, it is necessary to establish whether the test applies, and then determine which profits pass through the gate way and are chargeable profits of the CFC. Such profits are then subject to apportionment to the appropriate UK resident share holders. Profits that fall outside one gateway may still fall within one of the others.
Several safe harbors and specific exemptions exist with respect to the gateways, intended to narrow the scope to only artificially diverted profits. In particular, a company may make a claim that between 75% and 100% of profits arising from certain “qualify ing loan relationships” are exempt to the extent that they do not relate to UK significant people functions. The version of these rules as it existed up to 31 December 2018 is currently being considered in the context of the EU State Aid provisions.
The entity-level exemptions apply if any of the following circum stances exist:
• The CFC’s local tax liability is 75% or more of the equivalent UK liability.
• The CFC has low profits or a low-profit margin.
• The CFC is resident in certain qualifying territories.
• A foreign company has become a CFC for the first time (in certain circumstances).
Diverted profits tax. The diverted profits tax (DPT) is an antiavoidance measure, which is effective from 1 April 2015. It is aimed at perceived abuse in certain circumstances involving “in sufficient economic substance” somewhere in the supply chain or avoided UK permanent establishments. The DPT is separate from the corporation tax and is imposed at the rates listed below, on
profits diverted from the United Kingdom, broadly in the follow ing situations:
• A different transfer-pricing outcome allocating more profits to the United Kingdom and less to a low-tax entity would have resulted had all the facts, including the full supply chain and the activities undertaken by each entity in that chain, been consid ered.
• An alternative transaction would have been entered into in the absence of tax considerations, and it would have resulted in more taxable profits in the United Kingdom and less in a lowtax entity.
• A UK resident or nonresident carries on an activity in the United Kingdom in connection with the supply of goods, services or property by a non-UK trading company, and it is reasonable to assume that the activities are designed to ensure that no perma nent establishment is established in the United Kingdom, and certain other conditions are satisfied. An exclusion applies if the total UK-related sales revenues of the company (together with connected companies) that are not already included within the charge to UK corporation tax in a 12-month accounting period are less than GBP10 million. Likewise, an exclusion applies if the total UK-related expenses of the company (together with connected companies) in a 12-month accounting period are less than GBP1 million.
Exclusions apply based on substance and the relative values of the tax and other benefits of the transactions. Transactions are also excluded from DPT if they only give rise to one or more loan relationships and associated hedging derivatives. Notification requirements (which are broader than the tax-levying measures) and a unique charging mechanism are imposed with respect to DPT.
The following are the DPT rates:
• General rate: 25% (this rate will be increased to 31% from 1 April 2023)
• Diverted ring-fence or notional ring-fence profits: 55%
• Diverted profits that would have been subject to the bank sur charge: 33%
Patent Box. The Patent Box regime was introduced in 2012 and is effective for accounting periods beginning on or after 1 April 2013. The regime (which is optional) taxes qualifying income relating to patents and certain other IP at a rate of 10%. This rate was phased in over five years. Therefore, the 10% rate has been available on all qualifying income from patents and certain other IP since 1 April 2017.
The Patent Box regime applies to patents granted by UK and European patent offices and certain other patent offices in the European Economic Area, as well as to patent applications that cannot be published for reasons of national security or public safety. Other innovative IP found in the medicinal, veterinary and agriculture industries is also included, such as regulatory data, marketing exclusivity, supplementary protection certificates and plant variety rights.
The 10% effective tax rate is achieved by creating an additional deduction from taxable profits and applies to all income arising
from the patents, including royalties and income from the sale of patents. Significantly, it also applies to profits from the sale of products, services and processes with embedded patents.
Effective from 1 July 2016, the regime was amended in line with the recommendations of the OECD BEPS Action 5 report. For new entrants (new IP or new claimants) after 30 June 2016, an additional requirement is introduced into the regime. This require ment restricts the availability of the 10% tax rate if the claimant company has, to a significant extent, outsourced research and de velopment (R&D) to related parties or has acquired the IP. Qualifying income needs to be divided into substreams and then the nexus fraction applied (broadly based on the amount of R&D performed or outsourced by the company) to each income stream to determine how much income qualifies for the reduced tax rate. Existing IP in the regime as of 30 June 2016 should continue to qualify under the existing regime for up to a further five years.
Asset holding companies. The UK Asset Holding Company (AHC) regime was introduced from 1 April 2022 in order to provide a simplified basis of taxation for the holding companies of alternative investment funds. If a UK tax resident company meets the conditions to be a Qualifying AHC and has elected to be treated as such, it is able to benefit from a variety of tax exemptions and simplifications, including the following:
•
A simplified gains exemption that applies without any requirements in relation to the trading status of the underlying invest ment, holding period or ownership percentage
• An ability to return funds to investors in capital form for UK tax purposes and without incurring stamp duty
• An exemption from UK interest withholding tax on both thirdparty and shareholder debt
Dual-resident companies. A dual-resident company that is broad ly not a trading company loses the right to surrender its losses to fellow group members and is prevented from enjoying certain other reliefs. These rules effectively prevent such dual-resident companies from obtaining double reliefs in both countries of residence.
Impact of decisions of the Court of Justice of the European Union. Historically, the UK tax system has been subject to significant external influence in the form of binding decisions rendered by the Court of Justice of the European Union (CJEU).
Under the European Union (Withdrawal) Act 2018, now that the United Kingdom has left the EU, the existing body of EU law has been converted into British law so that the same rules applied following the end of the Brexit transition period as did before the end of the period. The UK parliament is now free, subject to in ternational agreements and treaties, to amend, repeal or improve any law as necessary. Following the end of the transition period on 31 December 2020, the CJEU has no general jurisdiction in the United Kingdom (though it has a specific role with respect to certain matters in the transition agreement). The UK courts are not required to consider post-Brexit CJEU case law but will in terpret the meaning of retained EU law by reference to relevant pre-Brexit CJEU case law.
Devolution of tax powers. Legislation enabling devolution of some corporation tax powers (including the power to set a Northern Ireland rate with respect to certain trading profits) to the Northern Ireland Assembly was enacted during 2015 and will take effect on a date to be determined by statutory instrument. To date, the power to set a Northern Ireland corporate tax rate has not been devolved, but a rate of 12.5% has been proposed. Although certain tax-raising powers have been devolved to the Scottish Parliament and Welsh Assembly (such as LBTT and LTT; see Section D), the power over corporation tax has not yet been devolved.
F. Treaty withholding tax rates
The rates in the table below reflect the lower of the treaty rate and the rate under domestic tax law. The table is for general guidance only.
Under UK domestic law, withholding tax is not imposed on divi dends.
Under the EU Interest and Royalties Directive, payments of inter est and royalties made between, broadly, associated companies resident in EU member states are exempt from withholding tax. In the United Kingdom, this directive was transposed into UK domestic legislation, but that legislation was repealed with effect from 1 June 2021. From that date, UK payers of interest and royalties will need to look to withholding tax provisions in the relevant double tax treaty in order to reduce or eliminate UK withholding tax on payments of interest and royalties out of the United Kingdom to EU-connected companies.
Anti-avoidance provisions may also restrict treaty benefits in certain circumstances. In particular, it will be necessary to con sider amendments to treaties through the mechanism of the Multilateral Instrument (MLI) as part of the G20/OECD’s BEPS initiative.
Payments by UK companies of Residence of Dividends Interest (a) Royalties (b) recipient % %
Albania 0 0/6 (x) 0
Algeria 0 0/7 (x) 10
Antigua and Barbuda 0 20 0
Argentina 0 0/12 (h) 3/5/10/15 (i)
Armenia 0 5 5
Australia 0 0/10 (k)(v) 5 Austria 0 0 0
Azerbaijan 0 0/10 5/10 (j)
Bahrain 0 0/20 (t) 0 Bangladesh 0 7.5/10 (k) 10
Barbados 0 0 0
Belarus 0 0/5 (y) 5
Belgium 0 0/10 (u) 0
Belize 0 20 0 Bolivia 0 0/15 15 Bosnia and Herzegovina (o) 0 10 10
Payments by UK companies of
Residence of Dividends Interest (a) Royalties (b) recipient % %
Botswana 0 0/10 10
Brunei Darussalam 0 20 0
Bulgaria 0 0/5 5
Canada 0 0/10 0/10 (a)
Chile 0 5/15 (b) 5/10 (f)
China Mainland 0 0/10 6/10 (r)
Colombia 0 0/10 10
Côte d’Ivoire 0 0/15 10
Croatia (o) 0 0/5 (v) 5 Cyprus 0 0 0
Czech Republic 0 0 0/10 (d)
Denmark 0 0 0
Egypt 0 0/15 15
Estonia 0 0/10 (v) 5/10 (f)
Eswatini 0 20 0
Ethiopia 0 0/5 (v) 7.5
Falkland Islands 0 0 0
Faroe Islands 0 0 0
Fiji 0 10 0/15 (j)
Finland 0 0 0
France 0 0 0
Gambia 0 0/15 (v) 12.5
Georgia 0 0 0 Germany 0 0 0
Ghana 0 0/12.5 (v) 12.5
Greece 0 0 0
Grenada 0 20 0
Guernsey 0 0 (dd) 0 (c)
Guyana 0 0/15 (v) 10/20 (n)
Hong Kong 0 0 3
Hungary 0 0 0
Iceland 0 0 0/5
India 0 0/10/15 (k)(v) 10/20 (f)
Indonesia 0 0/10 (v) 10/15 (f)
Ireland 0 0 0
Isle of Man 0 0 (dd) 0 (c)
Israel 0 5/10 0
Italy 0 0/10 (v) 8 Jamaica 0 0/12.5 (v) 10
Japan 0 10 0
Jersey 0 0 (dd) 0 (c)
Jordan 0 0/10 (v) 10 Kazakhstan 0 0/10 (v) 10
Kenya 0 0/15 (v) 15
Kiribati 0 20 0/20 (q)
Korea (South) 0 0/10 (v) 2/10 (e)
Kosovo 0 0 0
Kuwait 0 0 10
Latvia 0 0/10 (v) 5/10 (f)
Lesotho 0 0/10 (v) 7.5
Libya 0 0 0
Liechtenstein 0 0 0
Lithuania 0 0/10 (v) 5/10 (f)
Payments by UK companies of
Residence of Dividends Interest (a) Royalties (b) recipient % %
Luxembourg 0 0 5
Malawi 0 0/20 (l) 0/20 (l)
Malaysia 0 0/10 (v) 8
Malta 0 0/10 (v) 10
Mauritius 0 0/20 (k)(v) 15
Mexico 0 0/5/10/15 10
Moldova 0 0/5 (k)(v) 5
Mongolia 0 0/7/10 (k)(v) 5
Montenegro (o) 0 10 10
Montserrat 0 20 0
Morocco 0 0/10 (v) 10
Myanmar (Burma) 0 20 0
Namibia 0 20 0/5 (j)
Netherlands 0 0 0
New Zealand 0 0/10 (v) 10
Nigeria 0 0/12.5 (v) 12.5
North Macedonia (o) 0 0/10 (u) 0
Norway 0 0 0 Oman 0 0 8 Pakistan 0 0/15 (v) 12.5
Panama 0 0/5 (w) 5
Papua New Guinea 0 0/10 (v) 10 Philippines 0 0/10/15 (m)(v) 15/20 (p)
Poland 0 0/5 (v) 5 Portugal 0 10 5 Qatar 0 0 5 Romania 0 10 10/15 (j)
Russian Federation 0 0 0 St. Kitts and Nevis 0 20 0
Saudi Arabia 0 0 5/8 (e)
Senegal 0 0/10 (bb) 6/10 (aa)
Serbia (o) 0 10 10
Sierra Leone 0 20 0 Singapore 0 0/5 (k)(v) 8 (c)
Slovak Republic 0 0 0/10 (d) Slovenia (o) 0 0/5 (u) 5
Solomon Islands 0 20 0
South Africa 0 0 0 Spain 0 0 0
Sri Lanka 0 0/10 (k) 0/10 (s)
Sudan 0 15 10 Sweden 0 0 0 Switzerland 0 0 0
Taiwan 0 0/10 (v) 10
Tajikistan 0 0/10 7
Thailand 0 0/10/20 (k)(v) 5/15 (j)
Trinidad and Tobago 0 0/10 (v) 0/10 (j)
Tunisia 0 10/12 (k) 15
Turkey 0 0/15 (v) 10
Turkmenistan 0 0/10 (v) 10
Tuvalu 0 20 0
Uganda 0 0/15 (v) 15
Payments by UK companies of
Residence of Dividends Interest (a) Royalties (b) recipient
Ukraine
United Arab
United States
Uruguay
Uzbekistan
Venezuela
Vietnam
Zambia
Non-treaty jurisdictions
0/5 (v)
(z)
0/15 (cc)
0/10 (v) 10
0/5 (v) 5
0/5 (v) 5/7 (g)
0/10 (v) 10
0/10 (v) 5
0/10 (v) 10
20 20
(a) Withholding tax may not apply to interest paid with respect to loans from banks and insurance companies, securities quoted on a stock exchange, and certain sales of machinery and equipment.
(b) No withholding tax is imposed on royalties paid for copyrights of literary, dramatic, musical or artistic works (except motion pictures, films, videotapes and certain other items), payments for patents or commercial or industrial experience, or payments for the use of computer software.
(c) The 0% rate applies if the recipient is any of the following:
• The other state (including its local authorities, political subdivisions, local governments and statutory bodies)
• An individual
• A company whose shares are regularly traded on a recognized stock exchange
• A company of which less than 25% of its shares of which are owned by persons who are not residents of the other state
• A pension scheme
• A person who passes the “principal purpose test” set out in the treaty
(d) The higher rate applies to industrial, commercial, scientific, technical and technological royalties, and royalties with respect to patents, trademarks, designs or models, plans, and secret formulas or processes.
(e) The lower rate applies to payments for the use of, or right to use, industrial, commercial or scientific equipment. The higher rate applies to other royal ties.
(f) The lower rate applies to payments for the use of industrial, commercial or scientific equipment. The higher rate applies to other royalties.
(g) The 5% rate applies to royalties for patents, trademarks or processes as well as to royalties for know-how concerning industrial, commercial or scientific experience. The 7% rate applies to royalties for copyrights of literary, artistic or scientific works.
(h) The standard rate of withholding tax on interest is 12%. Interest is exempt from withholding tax if any of the following apply:
• The state is the payer of the interest.
• The interest is paid on a loan made, guaranteed or insured by the other contracting state.
• The interest is paid on a loan granted by a bank to an unrelated party at preferential rates and the loan is repayable over a period of not less than five years.
• The interest is paid on a debt resulting from either of the following:
— Sales on credit of industrial, commercial or scientific equipment by a resident of the other contracting state (excluding sales between related persons).
— Purchases of industrial, commercial or scientific equipment financed through a leasing contract.
(i) The 3% rate applies to royalties for the right to use news. The 5% rate applies to royalties for copyrights of artistic works (excluding motion picture films and television). The 10% rate applies to royalties for patents or payments for industrial experience, including the rendering of technical assistance. The 15% rate applies to other royalties.
(j) The lower rate applies to copyright royalties.
(k) A lower rate (the 7% rate under the Mongolia treaty and the 10% rate under the India and Thailand treaties) applies to interest paid to banks and other financial institutions.
(l) The higher rate applies if the recipient is a Malawi company that controls more than 50% of the voting power in the UK company that makes the payment.
(m)
The 10% rate applies to interest on listed bonds.
(n) The higher rate applies to cinematographic, television and radio broadcasting royalties.
(o) The UK tax authorities consider the former Yugoslavia treaty to be applicable to Bosnia and Herzegovina, Montenegro and Serbia. New agreements have been entered into with Croatia, Kosovo, North Macedonia and Slovenia.
(p) The lower rate applies to royalties with respect to cinematographic films and films or tapes for television or radio broadcasting.
(q) The higher rate applies to royalties with respect to mines, quarries or other extractions of natural resources.
(r) The lower rate applies to the right to use industrial, commercial or scientific equipment.
(s) The lower rate applies to copyright royalties. The higher treaty rate applies to all other royalties payable with respect to rights granted after the signing of the double tax treaty.
(t) The 0% rate applies to, among other interest payments, the following:
• Interest paid to the state (or a subdivision), an individual, a pension scheme, a financial institution, a quoted company or an unquoted company if it is less than 25% owned by Bahrain residents, provided that such interest is not paid as part of an arrangement involving back-to-back loans
• Interest paid by the state (or a subdivision) or a bank, or on a quoted Eurobond
(u) The lower rate applies to interest on loans between enterprises (20% relation ship required in the case of Slovenia), interest paid to a pension scheme (some treaties) or to a state or political subdivision.
(v) The lowest rate applies, depending on the treaty, to interest paid to a state or political subdivision or the central bank. Some treaties also apply this rate to interest guaranteed by or paid by the state.
(w) The lower rate applies if any of the following circumstances exists:
• The interest is paid to a state or political subdivision or the central bank.
• The interest is paid with respect to the sale on credit of merchandise or equipment to an enterprise of either country.
• The interest is paid as a result of financing provided in connection with agreements concluded between the two governments.
• The beneficial owner of the interest is a pension scheme.
(x) The 0% rate applies if any of the following circumstances exists:
• The recipient and beneficial owner of the interest is the other state or the central bank or a political subdivision or local authority thereof, a financial institution or a pension scheme.
• The interest is paid by the state in which the interest arises or by a political subdivision, or local authority thereof, or the interest is paid with respect to a loan, debt claim or credit that is owed to or made, provided, guaranteed or insured by that state or a political subdivision, local authority or export financing agency thereof.
• The interest is paid with respect to indebtedness arising as a result of the sale on credit of equipment, merchandise or services.
(y) The 0% rate applies if the recipient of the interest is the government of the other state, its central bank, an institution owned by that government, a statu tory body or a bank.
(z) Qualification for the lower rate may require certification by the relevant competent authority that one of a company’s main purposes is not the secur ing of the treaty relief.
(aa) An adjusted amount (60% of the gross amount of the royalties) is subject to the 10% rate with respect to the right to use industrial, commercial or scien tific equipment.
(bb) The 0% rate applies if the recipient of the interest is the government of the other state, its political subdivisions or local authorities thereof.
(cc) Relief may be restricted to 15% in certain circumstances (see Article 11(5) of the treaty).
(dd) The 0% rate applies if the interest is paid by the state in which it arises (including its political subdivisions, local authorities or statutory bodies), or if the recipient is any of the following:
• The other state (including its political subdivisions, local authorities, cen tral bank and statutory bodies)
• An individual
• A company whose shares are regularly traded on a recognized stock exchange
• A company of which less than 25% of its shares are owned by persons who are not residents of the other state
• A pension scheme
• A bank or building society
• A financial institution
A person who passes
The United Kingdom has also entered into tax treaties with Brazil, British Virgin Islands, Cameroon, Cayman Islands, Congo (Democratic Republic of), Iran and Lebanon. These treaties do not have articles covering dividends, interest or royalties. Payments to these countries are subject to withholding tax at the non-treaty countries’ rates set forth in the above table.
The United Kingdom also has new treaties, amendments or pro tocols to treaties with Belgium and Kyrgyzstan, which are signed but not yet in force. Most recently, it has indicated that it will prioritize renegotiation of treaties with EU member states to try to replicate the benefits of the EU Interest and Royalty and Parent and Subsidiary Directives, and an announcement with respect to a protocol to the Luxembourg treaty is expected. In addition, it has previously indicated that it was undertaking nego tiations with Costa Rica, Ghana, Kazakhstan, Lebanon, Malawi, Nepal and Peru.