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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.
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.
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. However, because of a wide range of exemptions, [217] very few companies suffer a CFC charge. [citation needed] Schedules B, C and E used to, but no longer, exist. [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.
Until 1993 the income tax rate payable on dividends was the same as all other income, and the ACT rate was adjusted to align it to changes in the basic rate of income tax. From April 1993, the ACT rate was cut to 22.5% while the tax rate on dividend income was set at 20%, the first time it was set at a different rate to that payable on other ...
A recipient of a fully franked dividend on the top marginal tax rate will effectively pay only about 15% tax on the cash amount of the dividend. In effect, when distributed as dividends, the profits of a corporation are taxed at the average of the shareholders' marginal tax rates; otherwise they are taxed at the corporate tax rate.
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The dividend received by the shareholders is then exempt in their hands. Dividend-paying firms in India fell from 24 percent in 2001 to almost 19 percent in 2009 before rising to 19 percent in 2010. [17] However, dividend income over and above ₹1,000,000 attracts 10 percent dividend tax in the hands of the shareholder with effect from April ...