资源描述
Click to edit Master title style,Click to edit Master text styles,Second level,Third level,Fourth level,Fifth level,*,ERGOSERVE CONSULTING LIMITED NICOS CHARALAMBIDES,UK INTERNATIONAL HOLDING COMPANIES,WHY THE UK?,DEFINITION OF A UK HOLDING COMPANY AND THE MAIN REQUIREMENTS THAT MUST BE OBSERVED,OTHER REQUIREMENTS,TAX AND OTHER ASPECTS,EXAMPLES,INCORPORATION&OPERATION,CONCLUSION,WHY THE UK?,UK HAS MANY COMPETITIVE,ADVANTAGES OVER OTHER,INTERNATIONAL HOLDING,COMPANY REGIMES,LARGEST NETWORKS OF DOUBLE TAX,TREATIES,OVER ONE HUNDRED,REPUTABLE JURISDICTION,EU MEMBER COUNTRY,EXCELLENT BUSINESS INFRASTRUCTURE,NO CONTROL ON MOVEMENT OF CAPITAL,DEFINITION OF A UK HOLDING COMPANY,THIS CAN BE A UK REGISTERED COMPANY AS WELL AS A FOREIGN REGISTERED COMPANY WHICH IS RESIDENT FOR TAX PURPOSES IN THE UK.THIS ALSO APPLIES TO THE UK BRANCHES OF FOREIGN REGISTERED COMPANIES,MAIN REQUIREMENTS,THE INVESTING COMPANY(OR HOLDING COMPANY)MUST HOLD AT LEAST 10%OF THE ORDINARY SHARE CAPITAL OF THE SUBSIDIARY COMPANY FOR AT LEAST 12 CONTINUOUS MONTHS(THE 12 MONTHS MUST NOT BEGIN MORE THAN 2 YEARS PRIOR TO THE DISPOSAL OF THE SHARES).,THE INVESTING COMPANY(OR HOLDING COMPANY)MUST BE A TRADING COMPANY BY ITSELF OR A HOLDING COMPANY OF A TRADING GROUP DURING THE 12 MONTHS PERIOD MENTIONED ABOVE.,THE SUBSIDIARY COMPANY MUST BE EITHER A TRADING COMPANY ITSELF OR THE HOLDING COMPANY OF A TRADING GROUP FOR THE WHOLE OF THE 12 MONTH PERIOD.,TRADING ACTIVITIES MEAN ACTIVITIES IN A TRADE,PROFESSION,OR VOCATION CARRIED ON,ON A COMMERCIAL BASIS WITH A VIEW OF GENERATING PROFITS.,SIMILAR PROVISIONS APPLY FOR GROUP COMPANIES.,OTHER REQUIREMENTS,THERE ARE ALSO OTHER REQUIREMENTS WHICH MUST BE MET,BOTH THE INVESTOR COMPANY AND ITS INVESTEE MUST MEET CERTAIN STATUS REQUIREMENTS THROUGHOUT THE QUALIFYING PERIOD OF 12 MONTHS AND IMMEDIATELY AFTER THE TIME OF DISPOSAL.,INVESTOR COMPANY,THE INVESTOR COMPANY MUST BE EITHER A STAND-ALONE TRADING COMPANY OR A MEMBER OF A TRADING GROUP THROUGHOUT THE QUALIFYING PERIOD AND IMMEDIATELY AFTER THE TIME OF DISPOSAL.,INVESTEE COMPANY,THE INVESTEE COMPANY MUST BE EITHER A TRADING COMPANY OR A HOLDING COMPANY OF A TRADING GROUP OR SUB-GROUP THROUGHOUT THE QUALIFYING PERIOD.,WHAT IS A GROUP OF COMPANIES FOR THE PURPOSE OF THE LEGISLATION?,A GROUP IS THE PRINCIPAL COMPANY AND ITS 51%SUBSIDIARIES OWED DIRECTLY OR INDIRECTLY,THE ACTIVITIES OF WHICH DO NOT“TO ANY SUBSTANTIAL EXTENT INCLUDE NON TRADING ACTIVITIES.INTRA GROUP ACTIVITIES ARE DISREGARDED.,WHAT IS THE DEFINITION OF TRADING?,TRADE MEANS ANYTHING THAT IS A TRADE,PROFESSION OR VOCATION,WHITHIN THE MEANING OF THE INCOME TAX ACTS,AND IS CONTACTED ON A COMMERCIAL BASIS WITH A VIEW TO THE REALISATION OF PROFITS,THESE ARE ACTIVITIES WHICH DO NOT TO ANY,SUBSTANTIAL EXTENT,INCLUDE,NON,TRADING ACTIVITIES,.TRADES WHICH THE COMPANY OR GROUP IS PREPARING TO OR INTENDING TO CARRY ON ARE INCLUDED AS TRADING ACTIVITIES.,SUBSTANTIAL EXTENT,IS CONSIDERED BY THE INLAND REVENUE TO MEAN MORE THAN 20%BUT IS UNCLEAR HOW IS TO BE MEASURED.THE INLAND REVENUE SAID THAT THIS MIGHT BE MEASURED BY REFERENCE TO TURNOVER,TO ASSET BASE,TO EXPENSES INCURRED OR MANAGEMENT TIME SPENT.,NON TRADING ACTIVITIES,NORMALLY,MAKING AN INVESTMENT THAT YIELDS INVESTMENT INCOME WOULD NOT COUNT AS TRADING ACTIVITY.,WHAT IS THE DEFINITION OF A TRADING COMPANY?,A TRADING COMPANY IS A COMPANY CARRYING ON TRADING ACTIVITIES WHOSE ACTIVITIES DO NOT INCLUDE,TO A SUBSTANTIAL EXTENT,ACTIVITIES OTHER THAN TRADING ACTIVITIES.,ACTIVITIES CARRIED ON BY A COMPANY WITH A VIEW TO ITS ACQUIRING A SIGNIFICANT INTEREST IN THE SHARE CAPITAL OF ANOTHER COMPANY THAT IS A TRADING COMPANY OR THE HOLDING COMPANY OF A TRADING GROUP OR SUB GROUP WILL BE REGARDED AS TRADING ACTIVITIES.HOWEVER,IF THE ACQUIRING COMPANY IS THE MEMBER OF A GROUP,THE COMPANY TO BE ACQUIRED MUST NOT BE A MEMBER OF THAT GROUP.,WHAT IS THE DEFINITION OF TRADING GROUP?,A GROUP OF COMPANIES,ONE OR MORE OF WHOSE MEMBERS CARRY ON TRADING ACTIVITIES,AND THE ACTIVITIES OF WHOSE MEMBERS TAKEN TOGETHER DO NOT INCLUDE,TO A SUBSTANTIAL EXTENT,ACTIVITIES OTHER THAN TRADING COMPANIES.,WHAT IS THE DEFINITION OF A HOLDING COMPANY OF A GROUP?,THE PRINCIPAL COMPANY OF THE GROUP,WHAT IS THE DEFINITION OF A HOLDING COMPANY OF A SUB-GROUP?,A COMPANY THAT WOULD BE THE HOLDING COMPANY OF A GROUP,BUT FOR BEING A 51%SUBSIDIARY OF ANOTHER COMPANY.,TAX ASPECTS,UK HOLDING COMPANY EXEMPT FROM CAPITAL GAINS TAX ON DISPOSAL OF ITS SHARES IN A SUBSIDIARY,NO CAPITAL DUTIES ON SHARE CAPITAL SUBSCRIPTIONS,NO MINIMUM PAID UP SHARE CAPITAL,(STG 50.000 FOR PLC),NO CAPITAL GAINS TAX ON SALES OF ASSETS SITUATED IN THE UK BY NON RESIDENTS,NO WITHHOLDING TAXES ON DIVIDENDS PAID TO UK NON RESIDENT SHAREHOLDERS,TAX RELIEF ON DIVIDENDS RECEIVED FROM FOREIGN COMPANIES,UK AS A MEMBER OF THE EU CAN BENEFIT FROM THE EU PARENT/SUBSIDIARY DIRECTIVE THEREBY REDUCING WITHHOLDING TAX TO ZERO ON DIVIDENDS FROM OTHER EU COUNTRIES,OTHER TAX ASPECTS,A UK INTERNATIONAL HOLDING COMPANY WHICH IS IN RECEIPT OF OVERSE
展开阅读全文