Given the close proximity and strong business ties with the UK, Denmark is an attractive location for UK companies to operate in. But what some companies may be unaware of is that, when undertaking work in Denmark, whether this be offshore or onshore, the UK company and its employees may have resultant Danish tax liabilities.
Rishi Sunak’s Autumn Budget will come as good news for individuals and trustees selling UK residential property. In his speech on 27 October 2021, the Chancellor announced provisions which will help to alleviate the compliance burden on those selling chargeable residential property by doubling the time available to report and pay Capital Gains Tax (CGT) from 30 to 60 days after completion.
The UK still provides significant UK tax mitigation strategies for overseas income sources where you are tax resident here, but not UK domiciled (Non Dom). HMRC are looking very closely at this group of individuals and have recently issued “Nudge letters” asking them if they are confident their tax liabilities have been reported correctly, particularly targeting those who have been resident in the UK for a number of years.
Section 18A of the Corporation Tax Act 2009 states that a UK resident company is entitled to make a Foreign Branch Exemption Election (“FBEE”). If a FBEE is made adjustments are required to be made in the calculation of the company’s total taxable profits. This means that any accounting profits or losses that arise in a foreign permanent establishment (“PE”) will not be included in the profits/losses chargeable to UK Corporate Income Tax (“CIT”).
On Saturday 5th June, the G7 countries, comprising of the United Kingdom, Canada, France, Germany, Italy, Japan and the United States, agreed to back an historic international agreement that will bring to fruition significant global tax reform at the end of 2021. This is a step towards tackling tax avoidance in international group operations. Following years of discussions, finance ministers agreed to reforms which will see multinationals pay their fair share of tax in the countries they do business.