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Fifth debate on Finance Bill

13 February 2018 / Allison Plager
Issue: 4635 / Categories: Comment & Analysis
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Overseas matters

KEY POINTS
  • Double tax relief restriction for overseas group companies.
  • Mandatory binding arbitration in double tax disputes.
  • Ensuring income paid to UK beneficiaries from offshore trusts is taxed.
  • Fixed mileage rate for landlords.

The taxation of companies operating overseas were the first subject for discussion in the Public Bill Committee’s fifth sitting. Financial Secretary to the Treasury Mel Stride said clauses 30 and 31 would ensure companies with foreign branches could not receive tax relief twice for the same loss. Clause 30 would address that by restricting double tax relief when the losses of an overseas branch have been used to relieve foreign tax paid by other overseas group companies. He said it would apply only to future claims for double tax relief but to ‘protect significant revenues’ would apply where...

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