International Manual Update Index - Recent changes to this manual
Below are details of amendments and new guidance published on 29
November 2006. (See the
update index for all updates).
The listed changes all relate to the Double Taxation Relief
module of the manual. The list does not include:
- minor text and formatting changes
- amended/additional hyperlinks
- changes to names and titles (e.g. Inland Revenue to HM Revenue and Customs) following departmental restructuring except to the extent that it shows the new recipients of referrals to the former Revenue Policy International, External Relations Group (Advisory).
UK RESIDENTS WITH FOREIGN INCOME OR GAINS: DOUBLE TAXATION RELIEF
UK RESIDENTS WITH FOREIGN INCOME OR GAINS: DOUBLE TAXATION RELIEF – CLAIMS AND PROCEDURES
UK RESIDENTS WITH FOREIGN INCOME OR GAINS: INCOME ARISING ABROAD
UK RESIDENTS WITH FOREIGN INCOME OR GAINS: DIVIDENDS
UK RESIDENTS WITH FOREIGN INCOME OR GAINS: INCOME TAX
UK RESIDENTS WITH FOREIGN INCOME OR GAINS: TRUSTS
UK RESIDENTS WITH FOREIGN INCOME OR GAINS: CORPORATION TAX
BANKS AND OTHERS LENDING BY WAY OF TRADE: LIMITATION OF FOREIGN TAX CREDIT RELIEF
UK RESIDENTS WITH FOREIGN INCOME OR GAINS: CAPITAL GAINS TAX
ANTI AVOIDANCE LEGISLATION
| Section
| Title and details of update
|
|
|
UK RESIDENTS WITH FOREIGN INCOME OR GAINS:
DOUBLE TAXATION RELIEF
|
| INTM161050
|
Deduction instead of creditCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
| INTM161130
|
The source rule – concessionsCentral Policy, Tax Treaty Team, FAO Technical Specialist
replaces Revenue Policy International, External Relations Group
(Advisory) for submissions.
|
| INTM161180
|
Statutory income basisThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) in the case of individuals and CT & VAT,
International CT in all other cases replaces Revenue Policy
International, External Relations Group (Advisory) for submissions.
|
| INTM161220
|
Foreign taxThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) in the case of individuals and CT & VAT,
International CT in all other cases replaces Revenue Policy
International, External Relations Group (Advisory) for submissions.
|
| INTM161250
|
Minimum foreign taxThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) in the case of individuals and CT & VAT,
International CT in all other cases replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
| INTM161270
|
‘Tax spared’ creditCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
| INTM161290
|
Referrals and reports to CT & VAT, International CTCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory).
|
| INTM161300
|
Unilateral reliefCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for referrals
|
| INTM161310
|
List of qualifying taxesCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for submissions.
|
|
|
UK RESIDENTS WITH FOREIGN INCOME OR GAINS:
DOUBLE TAXATION RELIEF – CLAIMS AND PROCEDURES
|
| INTM162030
|
CertificatesThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) in the case of individuals and CT & VAT,
International CT in all other cases replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
| INTM162100
|
Time limitsThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) in the case of individuals and CT & VAT,
International CT in all other cases replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
| INTM162110
|
Extended time limitsThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) in the case of individuals and CT & VAT,
International CT in all other cases replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
| INTM162130
|
Disputed claimsThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) in the case of individuals and CT & VAT,
International CT in all other cases replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
| INTM162160
|
Rate of exchange to useThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) in the case of individuals and CT & VAT,
International CT in all other cases replaces Revenue Policy
International, External Relations Group (Advisory) for submissions.
|
|
|
UK RESIDENTS WITH FOREIGN INCOME OR GAINS:
INCOME ARISING ABROAD
|
| INTM163020
|
Trade receiptsPage title ‘Trade receipts’ replaces ‘Measure
of income’.
|
| INTM163025
|
Trade receipts – FA2005 changesNew page
|
| INTM163030
|
Branch profitsCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for submissions.
|
| INTM163040
|
Branch profits – unrelieved taxDeleted text - previous penultimate paragraph: “If a UK
company has two or more branches in the same overseas country then
those branches can be amalgamated for the purposes of carrying
unrelieved tax forwards or backwards.”
|
| INTM163090
|
RoyaltiesAdditional text – new second paragraph and Example.
|
| INTM163110
|
DividendsCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for submissions.
|
| INTM163130
|
PartnershipsCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
| INTM163160
|
Artistes/athletes/sportsmenThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) replaces Revenue Policy International, External
Relations Group (Advisory) for referrals.
|
| INTM163190
|
Definition of government remunerationCentral Policy, Tax Treaty Team replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
|
|
UK RESIDENTS WITH FOREIGN INCOME OR GAINS:
DIVIDENDS
|
| INTM164020
|
Dividend articles in double taxation agreementsCentral Policy, Tax Treaty Team, FAO Technical Specialist
replaces Revenue Policy International, External Relations Group
(Advisory) for referrals
|
| INTM164100
|
Underlying taxCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for referrals
|
| INTM164110
|
(This text has been withheld because of exemptions in the Freedom of Information Act 2000)
(This text has been withheld because of exemptions in the
Freedom of Information Act 2000)
|
| INTM164120
|
Underlying tax – computation of relevant profitsCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for submissions.
|
| INTM164130
|
Underlying tax – dividend resolutionsAdditional text – the words “prepared at the time
the dividend was voted” in first paragraph.
|
| INTM164140
|
Underlying tax – minimising foreign tax paidCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
| INTM164150
|
Underlying tax - groups taxed as a single entity overseasAdditional text – new seventh paragraph.
|
| INTM164155
|
Tax deductions for dividendsNew page
|
| INTM164170
|
Underlying tax - pre-merger profits - dividends paid to the UK before 21 March 2000Underlying Tax Group in CT & VAT, International CT replaces
Revenue Policy International, External Relations Group (Advisory)
for submissions.
|
| INTM164235
|
Dividends received by UK companies on or after 2 December 2004 - the ADP mixer capNew page
|
| INTM164330
|
Dividends received by UK companies on or after 31 March 2001: eligible unrelieved foreign tax - group surrenderCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
| INTM164440
|
Determination of rates of foreign underlying tax – procedure
(This text has been withheld because of exemptions in the
Freedom of Information Act 2000) Revised text – seventh,
eighth and ninth paragraphs.
|
| INTM164443
|
Determination of rates of foreign underlying tax - procedure - information requirementsRevised documents and information requirements
|
|
|
UK RESIDENTS WITH FOREIGN INCOME OR GAINS:
INCOME TAX
|
| INTM165030
|
Computation – assessable amountThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) replaces Revenue Policy International, External
Relations Group (Advisory) for referrals.
|
| INTM165100
|
Overlap profitsThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) replaces Revenue Policy International, External
Relations Group (Advisory) for referrals.
|
|
|
UK RESIDENTS WITH FOREIGN INCOME OR GAINS:
TRUSTS
|
| INTM166030
|
Garland trustsThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) replaces Revenue Policy International, External
Relations Group (Advisory) for submissions.
|
|
|
UK RESIDENTS WITH FOREIGN INCOME OR GAINS:
CORPORATION TAX
|
| INTM167090
|
Apportion deductionsAdditional text - the final words: “or in respect of a
non-trading loss on intangible fixed assets of the surrendering
company treated as eligible for group relief (see ICTA88/S403(1)(b)
as amended by FA02/SCH30/PARA2)” at d..
|
| INTM167180
|
Loan relationships - mark to marketCT & VAT, International CT Revenue Policy International,
External Relations Group (Advisory) for submissions
|
| INTM167230
|
Loan relationships - credits on non-trading loan relationshipsCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
| INTM167430
|
Dividends - voting power reduced after 1st April 1972: extension of unilateral reliefCT & VAT, International CT replaces Revenue Policy
International, External Relations Group (Advisory) for referrals.
|
|
|
BANKS AND OTHERS LENDING BY WAY OF TRADE:
LIMITATION OF FOREIGN TAX CREDIT RELIEF
|
| INTM168005
|
Changes introduced by FA05/S86New page
|
|
|
UK RESIDENTS WITH FOREIGN INCOME OR GAINS:
CAPITAL GAINS TAX
|
| INTM169050
|
Not resident but ordinarily residentThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) replaces Revenue Policy International, External
Relations Group (Advisory) for submissions.
|
| INTM169080
|
Remittance basisThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) replaces Revenue Policy International, External
Relations Group (Advisory) for referrals.
|
| INTM169150
|
Amount of foreign tax credit relief - basis of allowanceThe Offshore Personal Tax Team (part of Charity, Assets &
Residence) replaces Revenue Policy International, External
Relations Group (Advisory) for submissions.
|
| INTM170000
|
ANTI AVOIDANCE LEGISLATIONNew chapter
|
