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Carpet Ltd is also subject to tax in Germany on the equivalent of £100,000 at a tax rate of 37%, or £37,000. The UK limits FTC to the amount of UK tax that would be on the foreign (non-UK) source income. If Carpet Ltd has no other foreign source income under UK concepts, Carpet Ltd's UK tax is £330,000 less FTC of £33,000, or £297,000.
As the UK has a considerable number of Double Tax Treaties, thus allowing the payment of income to non-UK residents without tax deduction, there may be limited appeal for QROPS. QROPS themselves do not dictate the tax position; it is the Double Tax Treaty that determines how a pension is taxed.
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.
Reduced income tax for special classes of person. For instance non-doms, who are resident in the United Kingdom but not "domiciled", are not subject to UK income tax on their non-UK income provided the remittance basis of taxation is claimed (or applies automatically) and the non-UK income is not remitted to the UK.
A new income tax law, passed in 1997 and effective 1998, determined residence as the basis for taxation of worldwide income. [168] The Philippines used to tax the foreign income of nonresident citizens at reduced rates of 1 to 3% (income tax rates for residents were 1 to 35% at the time). [169]
The list focuses on the main types of taxes: corporate tax, individual income tax, and sales tax, including VAT and GST and capital gains tax, but does not list wealth tax or inheritance tax. Personal income tax includes all applicable taxes, including all unvested social security contributions.