but subject to transfer pricing and thin capitalisation constraints (with no explicit safe harbours), hybrid mismatch rules (see General rules for trading expenses above), and the corporate interest restriction (CIR) rules (see below). Some of these rules apply to foreign exchange deductions relati...
Simultaneously with the release of The Transfer Pricing Records Regulations 2023, HMRC issued accompanying material within the transfer pricing sections of their International Manual, which provides guidance to HMRC officers and taxpayers on the UK’s application and interpretation of the aforementioned ...
If the Claimant refuses to accept the offer and proceeds with litigation and is awarded an amount of the claim which is less than the sum offered by the Defendant, the Claimant will be subject to the costs consequences and must pay the Defendant's legal costs with interest from the date th...
Cyprus Non-Dom tax benefits: As a Cyprus tax resident with non-domiciled status, you can benefit from the tax exemptions on dividend and interest income received from both local and foreign sources. This can be advantageous if you own shares in the Maltese company and receive dividends from it...
Client Account with Interest Client accounts for both general and designated use. An Interest-bearing client account for businesses or bodies who hold clients funds. Interest Paid Quarterly. Rates effective from 7th November 2024. Date from:£1+£25,000+£100,000+£250,000+£500,000+...
Local municipal taxes Local taxes are not based on income, but rather are levied on the occupiers of business property by reference to a deemed annual rental (or 'rateable') value for the property concerned. These taxes (known as 'business rates') are administered by regional local government...