Shareholder issues ― international corporate structures

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

How an international corporate group is structured can have a huge effect on the tax position of UK resident individuals who are shareholders. Sometimes it will be possible to amend the proposed structure to deal with any potential UK tax issues, but sometimes the impact of similar foreign tax rules (or completely different tax, company or regulatory rules) mean that alternative structures are not feasible for the international group.

The main issues that UK resident individuals should be aware of are:

•
gains made in the corporate structure may be taxable on the shareholders personally ― see the Gains attributable to participators in non-UK resident companies guidance note
•
income arising in the corporate structure may be taxable on the shareholders under the transfer of assets abroad rules
•
special rules apply to individuals holding shares in offshore funds

In addition, certain reliefs such as under the EMI or EIS schemes require that the group carries on business in the UK. However, other reliefs, such as business asset disposal relief (previously known as entrepreneurs’

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