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Bridging the Atlantic Series - UK tax regime: holding companies

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Summary: You should read this if you are a US business or individual investor interested in 'holding companies' within the UK.The UK tax regime “checks all the boxes” for a holding company location as a result of recent improvements to the UK corporate tax regime. Indeed, because of generous tax reliefs available under the UK tax regime, it is competitive with many traditional holding company locations.

In overview, the UK tax regime:

  • has a competitive tax rate
  • does not have a withholding tax on dividends;
  • provides many exceptions from its interest withholding tax rules
  • operates only a few restrictions on tax deductibility for finance costs;
  • offers an attractive low tax regime in respect of patent income;
  • provides a participation exemption for most capital gains;
  • exempts most inbound dividends (rather than operating a credit system);
  • has significantly relaxed its controlled foreign company regime (compared with the sub-Part F regime); and
  • offers large companies unparalleled access to HMRC specialist tax officials (“the Large Business Service”) in order to resolve uncertainty over the expected tax treatment.

For more information please read the full article on UK tax regime: holding companies.

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