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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.
Corporation tax is a tax levied in the United Kingdom on the profits made by companies and on the profits of permanent establishments of non-UK resident companies and associations that trade in the EU. Corporation tax forms the fourth-largest source of government revenue (after income, NIC, and VAT).
Non-resident companies can take advantage of a number of offshore regimes in order to reduce taxation, although in line with the elimination of unfair tax practices this is being phased out. Individuals pay quite high taxes on their income in Gibraltar unless they are able to take advantage of high-net-worth individual status or gain exemption ...
Japan: Dividends in Japan are taxed at a rate of 20% for non-residents, and 15% for residents. There is also a dividend exemption system that allows shareholders to exempt dividends from tax if they meet certain conditions. Germany: Dividends in Germany are taxed at a rate of 25% for non-residents, and 26.375% for residents. There is also a ...
[citation needed] The change had bigger effects on pensions and non-taxpayers. A pension fund receiving a £1.2 m dividend income prior to the change would have been able to reclaim £400,000 in tax, giving a total income of £1.6 m. After the change, only £300,000 was reclaimable, reducing income to £1.5 m, a fall of 6.25%. [citation needed]
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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The United Kingdom, prior to 2013, established three categories: non-resident, resident, and resident but not ordinarily resident. [125] 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]