International tax concepts ― overview

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Corporation Tax

Guidance

Common situations

International tax is relevant to a number of different situations, the most common of which are outlined below. Also, see the A–Z of international tax terminology guidance note for an explanation of some of the terms which are frequently encountered when advising on international tax matters, together with links to additional material.

Determining company residence

The concept of residence is important because it typically determines where a company is subject to tax. In the UK, corporation tax is chargeable on the worldwide profits of any company that is resident in the UK. A non-UK resident company is within the charge to corporation tax only if it carries on a trade here through a permanent establishment (PE). See the Residence of companies guidance note for further details.

Overseas company establishing in the UK

An overseas company establishing in the UK will need to determine if it has a PE here and

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Anne Fairpo

Barrister

With effect from 1 June 2021, Anne Fairpo is a judge of the First-tier Tribunal sitting in the Tax Chamber. She was previously a fee-paid judge in the same Chamber. Her contributions to LexisPSL Tax and TolleyGuidance were written before her full-time appointment and are her personal view as she is not authorised to write on behalf of the Tribunals Service or the judiciary. Until April 2021, Anne was a tenant at Temple Tax Chambers. She was called to the bar in 2009 after 15 years as a solicitor. Anne’s experience and expertise covers UK and international corporate tax planning and disputes, having acted for a range of clients from small owner-managed businesses to listed multinationals, as well as having advised on intellectual property taxation and UK-US cross-border tax planning, with regard to both direct and indirect tax matters

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