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UK companies in international tax planning PDF Print E-mail

UK companies can be very useful vehicles in international tax planning. Additionally, there are many commercial advantages in using UK companies. The UK is a reputable and "safe" jurisdiction from the legal and custodial points of view. The UK is one of the few jurisdictions which still allows holding of "bearer" shares to preserve confidentiality from public disclosure. There is commercial credibility in using UK companies. The UK has one of the largest tax treaty networks in the world, thus giving planning structures unrivalled treaty protection. The UK also has one of the lowest rates of corporate taxes compared to many other European countries. All of this enhances the commercial value added in using UK companies.

UK companies can be used for "holding" or "trading" structures. The UK is an excellent jurisdiction for basing a holding company as the "participation exemption" in now available (exemption from capital gains tax on disposals of substantial shareholdings). Dividends, interest or royalties may be routed through a UK company tax-advantageously. The UK is one of the few jurisdictions that does not impose a withholding tax on dividends paid out of the UK - even to a tax haven country!

UK companies are just as good tax planning vehicles in trading structures. Although a UK company is taxable on its worldwide income, "onshore-offshore" partnership structures may be employed to optimise the global tax burden on an organisation. Due to regulatory and harmful tax competition legislation, the trend in international tax planning is now towards the use of onshore-centric structures rather than purely offshore based structures. Therefore, where better than the UK for a relatively tax benign and cost-effective jurisdiction in international tax planning.

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