Inland Revenue

Inland Revenue

January 01, 1999 | By Keith Martin in Washington, DC

INLAND REVENUE issued interim guidance in December for companies with global trading desks in London on how much income from trades should be allocated to the United Kingdom. The guidance confirms that one way to keep such income outside the UK tax net is for a related party in another jurisdiction to supply the capital for the trades and assume the financial risk and pay a fee to the trading company for arranging trades. However, Inland Revenue said it would examine whether the person providing capital has a “permanent establishment” in the United Kingdom that would subject it to broader tax.