Management Fees Charged by a Foreign Parent to Its UK Subsidiary
UK Tax, Transfer Pricing, VAT and Documentation Requirements Foreign parent companies often provide management and support services to their UK subsidiaries. These services may include finance, HR, IT, legal support, marketing, strategic management and administration. The overseas parent may then charge the UK subsidiary a management fee. Although this is common within international groups, management […]
Intercompany Transactions Between UK Subsidiaries and Overseas Parents
Management Fees, Loans, Recharges, Transfer Pricing and VAT Foreign-owned UK subsidiaries frequently have financial transactions with their overseas parent companies or other group entities. These may include management fees, intercompany loans, interest, employee costs, software, professional services, royalties, shared group costs and goods. Although these transactions are common, they need to be properly accounted for […]
UK GAAP vs IFRS: Which Accounting Framework Should Your UK Subsidiary Use?
Executive Summary A foreign-owned UK subsidiary will usually prepare its statutory accounts under one of three frameworks: For many private UK subsidiaries, FRS 102 is the practical default. However, FRS 101 is often more efficient where the overseas parent reports under IFRS, because it can reduce differences between the UK statutory accounts and the group […]
Non-Resident VAT Registration: Special Rules for Overseas Sellers Without a UK Establishment
Executive Summary An overseas business without a UK establishment may have to register for UK VAT as soon as it makes, or expects to make, any taxable supply in the UK. The normal VAT registration threshold generally does not apply to a non-established taxable person, or NETP. This means even a small amount of UK […]
R&D Tax Credits for Foreign-Owned UK Subsidiaries: Are You Eligible?
Executive Summary Yes. A UK subsidiary can claim R&D tax relief even if it is wholly owned by an overseas parent. Foreign ownership does not disqualify the company. The UK subsidiary must be trading, subject to UK Corporation Tax and undertaking or commissioning a qualifying project that seeks an advance in science or technology. The […]
Annual Filing Obligations for Foreign-Owned UK Companies
Executive Summary A foreign-owned UK company has the same annual filing obligations as any other UK-incorporated company. Most private UK subsidiaries must: These filings have separate deadlines. Filing accounts does not replace the tax return, and the confirmation statement does not contain financial information. Filing Normal deadline Confirmation statement Within 14 days after the review […]
Hiring Staff in the UK as a Foreign Employer: PAYE Registration and Payroll Obligations
Executive Summary A foreign company can employ staff in the UK without first incorporating a UK subsidiary. However, hiring someone who works in the UK can create PAYE, National Insurance, pension, employment-law and tax obligations. Where the overseas employer has sufficient UK presence, it will normally need to: The employee may also create a UK […]
Transactions in Securities: Turning Dividends into Capital Gains
Company owners often have a choice about how to take money from their company. However, HMRC may challenge arrangements designed to turn dividend income into a more lightly taxed capital gain. These rules are known as the transactions in securities rules. Why do the rules exist? Dividends can be taxed at up to 39.35%, whereas […]
UK Gift Holdover Relief: Can You Give Away an Asset Without Paying CGT?
Giving an asset to your child or another family member may feel very different from selling it. However, for UK Capital Gains Tax purposes, a gift can still create a taxable capital gain—even though you receive no money. Gift Holdover Relief may allow that gain to be deferred. Here is how it works and when […]
Can You Still Claim Overseas Workday Relief After 6 April 2025?
Many internationally mobile employees believe that Overseas Workday Relief (OWR) ended on 6 April 2025. Fortunately, that isn’t always the case. If you moved to the UK before 6 April 2025 and claimed Overseas Workday Relief, you may still be able to continue claiming relief under the transitional rules, even if you do not qualify […]