Robert Langston considers the practical issues and opportunities arising from the new branch exemption introduced by FA 2011 Sch 13
Tony Beare’s article (‘The new branch exemption’ Tax Journal 17 June 2011) outlined the basic principles of the new foreign branch exemption.
This article outlines some of the practical issues and opportunities arising from the exemption which have already been identified in discussions with multinational groups.
The application of the exemption may be deferred where a branch has previously incurred losses effectively preventing double relief for losses where future profits will not be subject to UK tax.
In the draft legislation a brought-forward loss in one branch would defer the...
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