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2006-09-26 00:04:23 · 3 answers · asked by mmmporg 2 in Business & Finance Taxes United Kingdom

Difference of deemed tax and territorial basis of taxation.

2006-09-26 06:40:36 · update #1

3 answers

I think you are looking at the notion of territorial basis of taxation and deemed provision based on permanent establishment of a trade, business or profession in a country.

Use of foreign loans in the Country taxable on foreign entity:
Interest, commission fees or any other payments received as income, in connection with loans and debt through services of arrangement, management, guarantee, from resident persons or permanent establishment bearing the costs directly, or indirectly. Such loans must be used or brought into the Country. E.g. loans brought into the country to build a factory in the Country.

Any payment for the management or assistance in the management of any trade, business or profession:
Royalties or payments for the use of or the right to use knowledge or to render assistance in connection with the application of such knowledge, through any agreement or arrangement, and rent for the use of movable property. Except where it is applied against any business carried on outside or through a permanent establishment out of the Country.

Exclude, reimbursement or allocation of expenses between associate companies, claims from a head office neither tax resident nor of permanent establishment, and payment to persons not associated to payments in the Country.

Permanent establishment entails a fixed abode of business in which the business of the enterprise is wholly or partly carried on; or supervisory activities in connection with construction, installation or assembly project; or has income accruing or derived from the Country, or trades through agents that have in their capacity, authority to conclude contracts in its name or maintains stock for the purpose of delivery within the Country.

2006-09-26 02:16:10 · answer #1 · answered by pax veritas 4 · 1 0

This will depend on the type of business you intend to get invoved in. Either yourself or employing staff and working with other countries thro your own coy will be subject to import taxes and possible foreign taxes

2006-09-26 00:14:10 · answer #2 · answered by PAULA H 1 · 1 0

Please expand your question as the question in its current form makes no sense.

2006-09-26 00:13:53 · answer #3 · answered by Foxey 4 · 0 0

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