Double taxation relief
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
Interpretation
Meaning
Methods of relief
Mismatch
Mutual agreement procedure
Non-discrimination
OECD Model
Permanent establishment
Residence
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
Arbitration convention
Arbitration EC directive
Arrangement, meaning
Arrangements
Assessments to income tax and capital gains tax
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 gains tax
Carry-forward and set-off of losses
Causes of double taxation
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)
Source rule
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
Discretionary trusts
Discretionary trusts, payments out of
Disputes, solutions and mutual agreements
Dividend and tax credit, tax charge on aggregate
Dividends
Generally
Dual residence
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
Overlap profits
Overseas pensions
Overseas property
Partnership business carried on in Jersey
Partnerships
Patent rights
Petroleum revenue tax
Pioneer relief (tax spared)
Preventing
Primary taxing rights
Professional services
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
Sources of income
South Africa mutual assistance provisions, recovery of tax
Special withholding tax
Specified arrangemnets
Switzerland/UK agreement
Tax avoidance arrangements under Isle of Man scheme
Tax co-operation agreements
Tax credits
Generally
Incorrectly paid, recovery
Tax treaties
Termination payments, US/UK double tax agreement
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