A number of practical issues and opportunities arise from the new branch exemption introduced by FA 2011 Sch 13. Appropriate structuring can preserve relief for losses, but on a more basic level a company should consider the optimum timing for an election. Although the exemption seeks to align the tax treatment of branches and subsidiaries, there are still a number of important differences which need to be considered.
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A number of practical issues and opportunities arise from the new branch exemption introduced by FA 2011 Sch 13. Appropriate structuring can preserve relief for losses, but on a more basic level a company should consider the optimum timing for an election. Although the exemption seeks to align the tax treatment of branches and subsidiaries, there are still a number of important differences which need to be considered.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: