Accrued income scheme

Borne overseas tax

Generally

Advance corporation tax, set-off

Agreements

Admissible taxes

Basis of

Birth of

Domestic law, relationship with

Dual residence, individuals and companies

Exchange of information

Interpretation

Limitation of benefits

Meaning

Methods of relief

Mismatch

Mutual agreement procedure

Non-discrimination

OECD Model

Permanent establishment

Residence

Spared tax

Summary

Talks leading to

Tax co-operation agreements

Air transport

Alimony/maintenance payments under UK court order, payer resident abroad

Annual payments

Apportionment of interest of a foreign-controlled company

Apprentices

Arbitration convention

Arbitration EC directive

Arrangement, meaning

Arrangements

Assessments to income tax and capital gains tax

Bank levy

– see Bank levy

Beneficiaries

Bilateral relief

Agreements relating to estates, inheritances and gifts

Chronological list of double taxation orders

Estate duty agreements

Generally

List of agreements and pending agreements

Business profits

Calculation of relief available

Capital

Capital gains tax

Carry-forward and set-off of losses

Causes of double taxation

Chargeable gains

– see also Chargeable gains

Generally

Charges on income

Claims for relief

Companies

Generally

Company residence

Compensation or restitution for advance corporation tax

Infringement of non-discrimination articles

Reduction by tax credits

Construction industry contractors and subcontractors

Convention, meaning

Conventions

Corporation tax

Onward dividend to UK parent

Repayment of loans

Resulting reserve paid by way of dividend to overseas subsidiary

Series of intra-group transactions leading to declaration of dividends by overseas subsidiaries

Share subscription by overseas subsidiary in UK subsidiary

Shares cancelled by reduction in capital

Underlying tax limited to tax paid on true dividends taken to profit

Credit for foreign tax, calculation

Credit relief

Amount of foreign income assessable in UK

Ascertaining UK tax chargeable of foreign income and gains

Basis periods

Double counting, prevention

Duty to minimise foreign tax

Generally

Interest, dividends etc. as part of trading income

Limitation

Overlap profits

Pioneer relief (tax spared)

Residence requirements

Source rule

Special withholding tax deducted from EU savings income, relief for

Underlying tax on dividends

Credit relief for foreign tax

Deduction for foreign tax

Deduction for foreign tax where no credit allowed

Adjustment of amount payable, reduction too large or too small

Capital gain

Income

Transfer pricing

Delaware limited liability company, credit for tax paid in US

Directors' fees

Discretionary trusts

Discretionary trusts, payments out of

Disputes, solutions and mutual agreements

Dividend and tax credit, tax charge on aggregate

Dividends

Generally

Dual residence

Employees

Entertainers

Estate duty agreements

Deductions and exclusions

Domicile, meaning

Entry into force

Exchange of information

France

General definitions

India

Italy

Location of assets

Netherlands

Northern Ireland

Pakistan

Republic of Ireland

Republic of South Africa

Sweden

Switzerland

Tax credit provisions

Taxes covered

Termination

Territorial extension

Time-limits

United States of America

European cross-border transfers and mergers

Exchange of information

Generally

OECD Model

Statutory powers

Exemptions, effect of

Facilitating

Fiscal jurisdiction of the UK

Foreign banks on interest received from US corporations

Foreign income

Foreign interest and dividends

Foreign tax as expense

Foreign tax eligible for relief

Formula for calculating deductions

Forward contracts, entitlement under US Treaty to relief

Freedom of movement for workers, convention between France and Germany

General provisions

Generally

German trade tax paid by subsidiaries

Government service

History of

Inheritance tax

Business assets

Conflict as to nature of property

Current agreements

Deductions/allowances etc.

Diplomatic and consular officials

Entry into force

Exchange of information

Fiscal domicile

France

General definitions

Generally

Immovable property

India

Ireland, situs

Italy

Mutual agreement procedure

Netherlands

Non-discrimination

Pakistan

Personal scope

Republic of Ireland

Republic of South Africa

Ships, boats and aircraft

South Africa, securities

Sweden

Switzerland

Tax credits

Taxes covered

Taxing rights

Termination

Territorial extension

Time-limits

Transfers to spouses

Unites States of America

Inland waterways

Insurance company, Case I profit/pension business

Interest

International co-operation in tax matters

Know-how

Lloyd's underwriters

Mauritius, settlement and trustees' residence

Members of European Parliament

Methods of relief

Model treaty provisions

Mutual agreement procedure

Nature of relief

Netherlands company

Non-discrimination

Advance corporation tax

Group relief

Method of taxing UK branch or agency

Tax credit

Non-resident companies connected with unitary states, withdrawal of tax credit

Non-residents, payments out of UK discretionary trusts/estates

OECD developments

OECD Model Treaty

OECD/Council of Europe Convention for mutual administrative assistance in tax matters

Other income

Overlap profits

Overseas pensions

Overseas property

Partnership business carried on in Jersey

Partnerships

Patent rights

Pension income

Petroleum revenue tax

Pioneer relief (tax spared)

Preventing

Primary taxing rights

Professional services

Property income

Reference for a preliminary ruling

Repayment of tax resulting from carry back of unrelievable tax, restriction of interest

Residence

Royalties

Royalty payments

Self-assessment

Share of LLC profits taxed in US on basis that LLC 'transparent'

Shares and share options, internationally mobile employees and others

Shipping

Short-stay employees

Sources of income

South Africa mutual assistance provisions, recovery of tax

Special withholding tax

Specified arrangemnets

Sports persons

Students

Switzerland/UK agreement

Tax avoidance arrangements under Isle of Man scheme

Tax co-operation agreements

Tax credits

Generally

Incorrectly paid, recovery

Tax treaties

Teachers and professors

Termination payments, US/UK double tax agreement

Thin capitalisation

– see also Thin capitalisation

Generally

Transfer of moneys into Isle of Man trust

Transfer pricing

Treaty, meaning

Types of

UK resident companies holding shares in companies in EU states and non-member countries

UK resident companies paying dividends to overseas parent company

UK resident's share of profits of Jersey partnership

Unauthorised unit trusts

Basis periods

Generally

Underlying tax

Amount to be taken into account

Dividends

Dividends paid by overseas companies

Dual resident companies

Group as a single entity

Insurance companies

Losses

Portfolio investments

Split rate taxes

Trade investments

Unilateral relief

US limited liability companies

Unilateral relief

Exclusion of entitlement to

Foreign dividends

Foreign tax eligible for

Generally

Property situated both in UK and overseas territory

Property situated in overseas territory and not UK

Property situated neither in UK nor overseas territory

Property taxed in more than one overseas territory

Remuneration under contract

Underlying tax

Unilateral relief arrangements

Unrelieved foreign tax

Surrender within groups

Visiting teachers and researchers, two-year exemption period

Withholding dividends under UK/US tax treaty

Withholding tax, redemption of loan notes under material tax change provisions

Withholding taxes, reduction of