Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Accounting period definition

What does Accounting period mean? In practice, an accounting period is the span of time for which a company’s corporation tax is calculated and reported in its company tax return. It is a statutory concept for UK corporation tax (applied UK‑wide in England & Wales, Scotland and Northern Ireland) and for Irish corporation tax (defined in the Taxes Consolidation Act 1997). An accounting period usually aligns with the company’s period of account used for financial statements but cannot exceed 12 months. It begins when a company first comes within the charge to corporation tax and normally ends on the earliest of 12 months or the...

UK corporation tax: foreign branch exemption anti-diversion rules before 1 January 2013—tests, thresholds, safe harbours and HMRC guidance (archived)

Published by a LexisNexis Tax expert

Practice notes

ARCHIVED

This Practice Note has been archived and is no longer maintained. It deals solely with the anti-diversion rule applying to accounting periods beginning before 1 January 2013. For the rule that applies to periods after that date, see: Foreign branch exemption—anti-diversion after 1 January 2013

Purpose of the anti-diversion rule

The foreign branch exemption is constrained by an anti-avoidance measure intended to prevent a UK resident company from diverting profits away from the UK, ie to stop a UK company arranging for profits to arise in a foreign PE (and thus be exempt) rather than in the UK (where they would be taxable). This is known as the anti-diversion rule. The foreign branch exemption was introduced, alongside interim enhancements to the CFC regime, by Schedule 13 to the Finance Act 2011 (FA 2011)...

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Jisun Choi

Skadden

Jisun Choi advises a wide range of clients, including multinational corporations in various industries, private equity funds and financial institutions, on international and U.K. corporate tax matters, with a particular transactional focus on mergers and acquisitions and group restructurings, as well as associated financings.Ms. Choi’s practice involves structuring and advising on the tax aspects of:• private and public acquisitions and disposals of businesses, including management buyouts, sales of businesses in administration and auction sales• international group holding structures, including on joint ventures, the use of the U.K. as a holding company jurisdiction, and investment and asset management structures• group reorganisations and restructurings, including de-mergers of businesses and post-acquisition integration planning• capital market transactions, including initial and secondary listings of equity and debt instruments, and return of value to shareholders• banking and derivative transactions, including bank credit facilities and private placement arrangementsIn addition, Ms. Choi has...

Web page updated on 22/05/2026

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