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23 Mar 2011

Government aims to stop exodus from the UK with super-low rate of corporation tax for finance companies

Elliot Weston, corporate tax partner, Lawrence Graham LLP: "The Government has moved to encourage UK groups to remain in the country by permitting their overseas group treasury companies to be subject to a very low effective rate of UK tax, potentially just 5.75%.

"As part of the proposed changes to the taxation of controlled foreign companies, there is to be introduced in 2012 a partial exemption for group finance companies. The Government is effectively proposing a minimum debt: equity ratio of 1:3.

"The proposal is that the profits of overseas group financing arrangements would be taxed at an effective UK tax rate of one-quarter of the main corporation tax rate (i.e. ¼ of 23% from 2014 would be an effective rate of 5.75%)."

Elliot Weston
Partner, Corporate Tax
Elliot Weston
.