Recent updates to the International Manual
Below are details of the amendments that were published on 16 September 2009 (see the update index for all updates)
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Details of update |
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UK subsidiaries of foreign banks and foreign banks trading in the UK through permanent establishments. New subsection within the International Manual to re-house material which was contained within the HM Revenue and Customs Banking Manual [BAM]. |
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UK subsidiaries of foreign banks and foreign banks trading in the UK through permanent establishments. New chapter which covers foreign banks trading in the UK through a permanent establishment (INTM267620), treaty claims and the EU interest and royalties directive (INTM267630), transfer pricing legislation (INTM267640) and representative offices (INTM267650). |
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Foreign banks trading in the UK through permanent establishments - The charge to corporation tax (contents). New page - covering the charge to corporation tax (INTM267621), attribution of profits to a permanent establishment (INTM267622), transfer of loans (INTM267623), attribution of financial assets and split function business (INTM267624), tax deduction for interest paid in the ‘ordinary course of business’ (INTM267625) and interaction of double taxation agreements with UK domestic law (INTM267626). |
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UK subsidiaries of foreign banks and foreign banks trading in the UK through permanent establishments. New page - covering treaty claims and the EU interest and royalties directive. |
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UK subsidiaries of foreign banks and foreign banks trading in the UK through permanent establishments (Contents). New page - covering transfer pricing legislation - thin capitalisation (INTM267642). |
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UK subsidiaries of foreign banks and foreign banks trading in the UK through permanent establishments. New page - covering representative offices. |
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The attribution of capital to foreign banking permanent establishments in the UK (Contents). New page - covering what is capital for a bank, and what does it do with it? (INTM267701), Free working capital (INTM267702), the FA03 legislation (INTM267705), the approach in determining an adjustment to funding costs under ICTA88/S11AA - overview of the five steps (INTM267706), the approach in determining an adjustment to funding costs under ICTA88/S11AA - STEP 1: Attributing the assets (INTM267707), STEP 2: Risk weighting the assets (INTM267710), STEP 2: Risk weighting the assets - the Basel II regulatory regime (INTM267730), STEP 3: Determining the equity capital (INTM267760), STEP 4: Determining the loan capital (INTM267770), STEP 5: Determining the capital attribution tax adjustment (INTM267780), alternative approaches to calculating the capital attribution tax adjustment (INTM267795), the application of ICTA88/S11AA to permanent establishments of UK companies (INTM267796), Double Taxation Relief problems: Mutual Agreement Procedure (INTM267797) and the use of UK Generally Accepted Accounting Practice (INTM267798). |
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The attribution of capital to foreign banking permanent establishments in the UK (Contents). New page - covering the approach in determining an adjustment to funding costs under ICTA88/S11AA - STEP 2: Risk weighting the assets. This includes risk weighting the assets - background (INTM267711), host v home state regulation (INTM267712), Financial Services Authority regulatory rules (INTM267713), use of the regulatory framework (INTM267714), the banking book: on-balance sheet items (INTM267715), the banking book: off-balance sheet items (INTM267716), the banking book: funding off-balance sheet items (INTM267717), over-the-counter derivatives (INTM267718), risk in the trading book (INTM267719), large exposures (INTM267720), the use of risk models (INTM267721), intra-company transactions and assets (INTM267722), intra-company netting of third-party assets (INTM267723), inter-company transactions (INTM267724) and treasury functions (INTM267725). |
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Foreign banks trading in the UK through permanent establishments (Contents). New sub-chapter - covering the approach in determining an adjustment to funding costs under ICTA88/S11AA - STEP 2: Risk weighting the assets - the Basel II regulatory regime. This includes: step 2 under Basel II (INTM267731), the three pillars (INTM267732), pillar 1 (INTM267733), pillar 1 - credit risk (INTM267734), Pillar 1 - simplified standardised approach to credit risk (INTM267735), Pillar 1 - use of external credit assessment institutions (INTM267736), Pillar 1 - simplified standardised approach to credit risk (INTM267737), Pillar 1 - internal rating based approaches to credit risk (INTM267738), Pillar 1 - types of internal rating based approaches to credit risk (INTM267739), Pillar 1 - trading book issues including market risk (INTM267740), Pillar 1 - operational risk (INTM267741), Pillar 1 - the basic indicator approach to operational risk (INTM267742), Pillar 1 - the standardised approach to operational risk (INTM267743), Pillar 1 - the alternative standardised approach to operational risk (INTM267744), Pillar 1 - advanced measurement approaches (INTM267745), Pillar 2 (INTM267746), Implementation of Basel II (INTM267747), the thin capitalisation principle (INTM267748), the interim period (INTM267749), use of Basel II approaches (INTM267750), reporting (INTM267751), Operational and Pillar 2 risk (INTM267752), Risk assessment of UK branches of foreign banks following implementation of Basel II (INTM267753), end of the interim period (INTM267754) and overseas branches of UK-resident banks (INTM267755). |
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The attribution of capital to foreign banking permanent establishments in the UK (Contents). New page - covering the approach in determining an adjustment to funding costs under ICTA/S11AA - STEP 3: Determining the equity capital. This includes Determining the equity capital: overview (INTM267761), Tiers 1, 2 and 3 (INTM267762), Tier 1 capital (INTM267763), Tier 2 capital (INTM267764), Tier 3 capital (INTM267765), the treatment of retained profits and losses (INTM267766), interest-free loans (INTM267767), permanent establishments funded entirely by borrowing in local markets (INTM267768) and the arm’s length amount (INTM267769). |
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The attribution of capital to foreign banking permanent establishments in the UK (Contents). New page - covering the approach in determining an adjustment to funding costs under ICTA88/S11AA - STEP 4: Determining the loan capital. Includes: Overview (INTM267771), Tax-efficient mix of capital (INTM267772), Innovative or hybrid Tier 1 capital (INTM267773), Tier 2 subordinated debt (INTM267774) and Exceptional circumstances - no tax-deductibles capital in the home territory (INTM267775). |
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The attribution of capital to foreign banking permanent establishments in the UK (Contents). New page - covering the approach in determining an adjustment to funding costs under ICTA88/S11AA - STEP 5: Determining the capital attribution tax adjustment. This includes disallowance of interest and other costs on funding equivalent to attributed equity - overview (INTM267781), disallowance of interest and other costs on funding equivalent to attributed equity - an example (INTM267782), the range of capital attribution adjustment (INTM267783), allowance for potential additional interest costs and other costs on loan capital attributed to a permanent establishment (INTM267784), multi-currency books and the currency/interest rates to be used in arriving at the disallowances and allowances for equity and loan capital (INTM267785), equity capital already allotted exceeding amount computed under the legislation (INTM267786), equity capital attributed but no funding costs in the UK permanent establishment (INTM267787), guarantee fees - no deduction available (INTM267788), frequency of calculations (INTM267789) and allotment of capital (INTM267790). |
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UK residents with foreign income or gains: double taxation relief - claims and procedures. Certificates of Residence; alteration to who is authorised to sign the certificate of residence (it is now an HM Revenue and Customs officer within the claimant’s tax office rather than the claimant’s Inspector). |
