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A controlled foreign company ("CFC") is a company controlled by a UK resident that is not itself UK resident and is subject to a lower rate of tax in the territory in which it is resident. Under certain circumstances, UK resident companies that control a CFC pay corporation tax on what the UK tax profits of that CFC would have been.
There was a matching reduction in the basic income tax rate on dividends to 10%, while a new higher-rate of 32.5% was introduced which led to an overall effective 25% tax rate for higher rate taxpayers on dividends (after setting this "notional" tax credit against the tax liability).While non-taxpayers were no longer able to claim this amount ...
Under such systems, generally the amount of credit is the foreign taxes paid by the foreign corporation times the fraction of earnings distributed to the shareholder as a dividend. Generally, the amount of dividend is "grossed up" for the amount of available credit, before limitations, effectively charging the shareholder with home country tax ...
Australia: Dividends in Australia are taxed at a rate of 30% for non-residents, and 15% for residents. There is also a dividend imputation system that allows shareholders to claim a credit for the taxes that the company has already paid on its profits. Japan: Dividends in Japan are taxed at a rate of 20% for non-residents, and 15% for residents.
A non-domiciled UK resident earning less than £2,000 in a year outside the UK does not pay tax on this unless it is transferred to the UK. This would apply to the typical person taking up a temporary job in the UK, being paid, and paying tax on it, in the UK, with possible additional small earnings in the home country.
Dividend imputation was introduced in 1987, one of a number of tax reforms by the Hawke–Keating Labor Government. Prior to that a company would pay company tax on its profits and if it then paid a dividend, that dividend was taxed again as income for the shareholder, i.e. a part owner of the company, a form of double taxation.
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From 2013, the categories of resident are limited to non-resident and resident. Residency is established by application of the tests in the Statutory Residency Test. [126] The United States taxes its citizens as residents, and provides lengthy, detailed rules for individual residency of foreigners, covering: