A company resident in the UK that is under the control of five or fewer participators or any number of participators who are also directors.
A Controlled Foreign Company (CFC) is a foreign-based corporation that is controlled by residents of the home country, allowing individuals or companies to potentially shift profits and reduce their tax liabilities.
A parent undertaking and its subsidiary or subsidiaries. In UK tax law, two or more companies constitute a group where one company holds more than 50% of the shares in the other(s). This test is usually applied to the voting share capital only. Where there is a group of companies, the availability of the lower rates of corporation tax is restricted.
A detailed explanation of the classification of higher-paid employees under UK tax law, encompassing remuneration, benefits, and reimbursed expenses.
In the UK Capital Gains Tax rules, an individual 'ordinarily resident' is subject to the tax even if they are not actually living within the UK. This status applies to various scenarios such as imprisonment abroad or taking a gap year.
In UK tax law, the Ramsey Principle allows the court to examine a series of connected transactions collectively to ascertain the taxpayer's liability, rather than isolating each individual transaction.
The Westminster Doctrine refers to the principle in UK tax law that individuals and entities may arrange their financial affairs to minimize tax liability. It originated from the 1936 ruling in Commissioners of Inland Revenue v the Duke of Westminster.
