Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Rules definition

What does Rules mean? Rules describes the written provisions that govern how a pension scheme operates—especially occupational pension schemes—usually contained in, or annexed to, the trust deed (trust deed and rules). Legislation refers to these as scheme rules (for example, Pensions Act 1995 and Pensions Act 2004 in the UK, and the Pensions Act 1990 in Ireland). Scheme rules set out eligibility, benefit structure (defined benefit or defined contribution), contributions, service and accrual, retirement options and ages, revaluation/indexation, ill‑health and death benefits, transfers in and out, leaver provisions, forfeiture, augmentation, priority on winding‑up, discretions and decision‑making, and the scheme’s amendment and termination powers. They also...

UK foreign branch exemption—special rules affecting capital gains, intangible fixed assets, capital allowances (leasing/disposal), CFC, withholding tax, CIR and other corporation tax provisions

Published by a LexisNexis Tax expert

Practice notes

As set out in Practice Note: Foreign branch exemption—foreign permanent establishments amount, specific rules govern how to compute the foreign permanent establishments amount (FPEA), in order to determine exactly what portion of a company’s profits should be relieved from UK tax under the foreign branch exemption, and how those calculations must be applied...

However, a UK company’s election to exclude profits attributable to its overseas permanent establishments (PE) from UK tax could both:

affect the other taxes payable by the UK company; and
be counteracted by existing rules within those other taxes

This Practice Note sets out certain special rules introduced to ensure the tax system, taken as a whole, continues to operate as intended, and summarises their interaction in the following broad areas:

capital gains
intangible fixed assets
capital allowances
other provisions

Capital assets—no gain no loss

There are various provisions in the Taxation of Chargeable Gains Act 1992 (TCGA 1992) that apply the ‘no gain no loss’ principle; a comprehensive list of those provisions appears in TCGA 1992, s 288(3A)...

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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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