SOURCE CURRENCY
5th Edition, July 2018

This new edition identifies the features of the UK company and the UK corporation tax regime that are advantageous to international business. This is an important topic at a time when significant numbers of investors are transferring assets from offshore companies to companies registered in ‘mid shore’ jurisdictions such as the UK, in response to a tide of penal legislation being targeted at the world’s offshore financial centres.


The fifth edition includes the following:

• UK corporation tax and company residence including analysis of the 2017 case of Development Securities
• The OECD BEPS project and its Multi-lateral Instrument, and the practical implications of these developments
for UK companies and international business
• The new opportunities created by the UK’s 2017 legislative reforms to the substantial shareholder exemption
• Updated case studies throughout the book on uses of UK companies for international business
• Review of the main UK anti-avoidance legislation pertaining to UK companies
• Assessment of the UK company’s new ‘beneficial owners’ register, and the impact of offshore companies and
trusts on this transparency regime