Closed consultation

Taxation of foreign branches

This consultation was published under the 2010 to 2015 Conservative and Liberal Democrat coalition government

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Original consultation

This consultation ran from to

Summary

Options to reform the taxation of foreign branches of UK companies

Documents

Corporate Tax Reform part 3B: Foreign branch taxation (PDF  190KB)

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Exemption for profits of foreign permanent establishments etc (“foreign branch exemption”) - technical note (PDF 66KB)

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Summary of responses to the consultation on the taxation of foreign branches which closed on 11 February 2011 (PDF 207KB)

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Minutes from the seventh meeting of the Taxation of Foreign Branches Working Group, 22 February 2011 (PDF 79KB)

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Minutes from the sixth meeting of the Taxation of Foreign Branches Working Group, 2 February 2011 (PDF 79KB)

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Minutes from the fifth meeting of the Taxation of Foreign Branches Working Group, 14 January 2011 (PDF 79KB)

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Consultation description

Announcements and updates

**25 July 2011: **Updated draft guidance on the foreign branch exemption legislation has now been issued and is available on the HMRC website (link opens in a new window)

**30 June 2011: **The Controlled Foreign Company Reform consultation which includes details of the application of the rules to exempt foreign branches has been published.

**23 May 2011: ** Clause 48 and Schedule 13 of the Finance Bill give an optional exemption from Corporation Tax for profits attributed to a foreign permanent establishment. Read the ‘Draft guidance on foreign branch exemption legislation (HMRC website, opens in a new window)

**01 April 2011: ** The Finance (No 3) Bill was presented to Parliament on 29 March 2011. The legislation for the reform to the taxation of foreign branches (Clause 48, Schedule 13) is available on the parliament website (external website, opens in anew window).

Consultation

The Government is currently examining options to reform the taxation of foreign branches of UK companies and is consulting on an opt-in exemption from corporation tax for the profits of foreign branches of UK companies. The intention is to introduce new rules in Finance Bill 2011.

On 29 November 2010 the Government published Corporate Tax Reform: Delivering a More Competitive System.

On 20 December 2010 the Government published a technical note on the draft legislation to provide additional information not within the scope of the Explanatory Note.  It includes details on the relation between the draft legislation and the OECD Model Tax Convention, and matters not covered in the draft legislation, as well as questions for interested parties.

Documents published prior to 29 November 2010 as part of the Government’s review of the taxation of foreign branches.