New queries, issue 4275

A nutty problem

We have a UK parent company client which operates through a number of 100% subsidiary companies situated all over the world.

If one of the companies with dual residency (Brazil and UK) makes losses can we utilise those current year losses as group relief in the UK and still be able to carry the loss forward in the foreign country as well?

I would mention that Brazil does not have a double taxation treaty with UK. All the companies in the group are trading companies.

Any guidance from Taxation readers would be helpful.

Query 17 688 – Brazil Nut

Currency gains

I wonder if any Taxation readers can provide some advice on the following topic.

A gain on foreign currency acquired by an individual for personal expenditure outside the UK (including the provision or maintenance of any residence outside the UK for himself his family...