Includes the new foreign dividend and substantial shareholder tax exemptions The new rules regarding the foreign dividend tax exemption present a seismic change to the landscape of international tax planning. The changes further consolidate the UK's standing as one of the most tax-efficient corporate domiciles. International Tax Planning Using UK Companies is a new publication which expands and updates UK International Holding Companies which was last published in 2003. It is intended to examine the potential of the UK company as an offshore company and therefore covers not just the recent legislative changes that strengthen the UK as an international holding company location, but also considers other applications of the UK company in offshore tax planning. The book therefore addresses the interest being shown in the UK company as an offshore vehicle by offshore trust companies, entrepreneurs and finance directors in the emerging markets of Eastern Europe, South America and South East Asia. Offshore Tax Planning Using UK Companies analyses the advantages of UK companies in international tax planning. In many cases the UK company can prove more tax-efficient than a typical offshore company. The book updates the CGT exemption rules for UK holding companies introduced in 2002 and assesses the international tax planning opportunities of the new foreign dividend tax exemption which was introduced on 1st July 2009.

The book also examines the tax benefits of the UK company as an international trading company and as a recipient of various kinds of non-UK-source revenue. This book explains relevant EU and UK legislation, the operation of double tax treaties, as well as case study examples illustrating offshore tax planning possibilities using UK companies. It is essential reading for corporate and tax lawyers and accountants in the UK and overseas, finance directors of large UK overseas companies, and offshore trust companies. CONTENTS Introduction Foreign withholding taxes The new taxation exemption for foreign dividends Company residence UK withholding tax and UK dividends, royalties and interest payments Tax exemption for capital gains Anti-avoidance Other uses of UK companies, LLP's and Limited Partnerships in international tax planning UK trusts and trustees UK company formation and administration with updates arising from the UK Companies Act 2006.