HMRC Admin 13 Response
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RE: Tax paid but now being chased for non payment.
Thank you for the original query from pipuk68 and Kerry-Ann for your helpful response. Please contact our CT helpline on 0300 200 3410. Our colleagues will be able to assist you further regarding this query. -
RE: Pension contributions to director's SIPP.
Thank you for your query.
Please see: ETASSUM29000 - Schedule 2 share incentive plan (SIP): Taxation: Contents - HMRC internal manual
If you require further advice on this matter, please seek professional help through a financial advisor or accountant. -
RE: Double tax treaty
Thank you for your query.
If you live in a country that has a double taxation treaty with the UK giving relief from UK Income Tax, you can use form DT Individual to apply for the relief at source and claim a repayment of UK Income Tax.
Please see Double Taxation: Treaty Relief (Form DT-Individual) -
RE: Losses of trades carried on wholly or partly in the UK accumulated over several tax years.
Thank you for your query. Your computations for each Accounting Period should include a detailed calculation of losses, deficits and excess amounts.
Please see The Company Tax Return guide.
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RE: Foreign Limited Company taxable in UK?
The general rule is that a company which is not resident in the UK has to pay UK Corporation Tax only if:
• it has a permanent establishment in the UK
• the economic activity that generates its profits is carried out in the UK
Further guidance on company residence can be found at INTM120210 - Company residence: guidance originally published in the International Tax Handbook - HMRC internal manual -
RE: Interest on loan between connected companies
As previously advised, the general rule is interest paid is tax deductible and interest received is taxable by reference to when it is accrued, rather when it is paid or received.
Special rules apply where there is a delay in paying the interest.
You can find HMRC guidance on this topic at CFM35800 - Loan relationships: connected parties: late interest: Contents - HMRC internal manual