Business Environment

Company Tax

• 25% standard rate
• 19% for companies whose profits do not exceed GBP 50,000

Tax Rate For Foreign Companies

Resident companies are taxable in the United Kingdom on their worldwide income.
A non-resident company is subject to UK corporation tax only on the trading profits of a UK permanent establishment or the trading profits attributable to a trade of dealing in or developing UK land (even if there is no PE in the UK). From 6 April 2020, non-UK resident companies including those who invest in UK property through collective investment vehicles will need to pay corporation tax instead of income tax on profits from UK property. Any other UK-source income received by a non-resident company is subject to UK income tax at a rate of 20%, without any allowances.

Capital Gains Taxation

Capital gains of a company are considered taxable profits but are exempt if they arise from the disposal of substantial shareholdings in both UK and foreign companies. Substantial shareholding is often defined as an interest in a minimum of 10% of an investee company for a period of 12 months in the six years preceding the purchase. Non-resident companies are generally not subject to capital gains tax unless gains are obtained by their permanent establishment in the UK.
From April 2019, gains from the disposal of UK property and certain UK property-related investment assets by non-residents are subject to UK tax. For disposals prior to April 2019, the scope of the charge is restricted to disposals of UK residential property only, and to narrower categories of non-resident persons.
Capital losses are allowed only as an offset to capital gains.
Gains realised on certain types of assets - such as land and buildings used for a trade - can be deferred where all or most of the proceeds are reinvested in other assets of those types within a certain period (generally three years - so-called "rolled-over").

Main Allowable Deductions and Tax Credits

For company taxation purposes, total profits are the total of (i) the company's net income from each source (trade, property business, interests, dividends, etc.) and (ii) the company's net chargeable gains arising from the sale of capital assets. The rules governing expense deductibility vary according to the type of income the expenses relate to.
In general, all expenses that are not capital in nature and that are used for trading purposes are deductible. Local municipal taxes are generally deductible. Interest is deductible within the debt cap rules that apply to companies that are members of large groups. Most donations to charities are tax-deductible. Provisions for future costs can be deducted for tax purposes under certain conditions.

An R&D tax credit is available at 13% of R&D expenditure for large companies (such credit is taxable so that the net benefit to the company is 10.5% - the rate increased to 20% from 1 April 2023, for a benefit of 15%), while SMEs can claim a tax deduction of up to 230% of their R&D expenditure (reduced to 186% from 1 April 2023). A patent box regime is gradually being introduced over 5 years to allow companies to apply an effective 10% rate to all profits derived from qualifying patents. Special tax reliefs are available for expenditures on the production of movies, animation, video games, high-end TV shows and orchestral concerts.

Operating losses can be offset by the profits of the current fiscal year while the exceeding loss can be carried forward to the previous year. Operating losses incurred prior to 1 April 2017 can be carried forward indefinitely and offset by operating profits from future tax years. Operating losses incurred after 1 April 2017 can be offset by any type of profit. In both cases, the maximum carried forward loss offset is broadly limited to GBP 5 million plus 50% of the current year's profits in excess of that amount.
Capital losses can only be offset by capital gains and their carryback is prohibited. For accounting periods ending on or after 1 April 2020, the use of carried-forward capital losses is limited to 50% of gains above a groupwide GBP 5 million allowance per year (shared between capital and non-capital losses).

Other Corporate Taxes

A general anti-abuse rule (GAAR) applies across a range of taxes on transactions made after 17 July 2013.

The United Kingdom imposes a 30% tax on profits generated from oil or gas extraction and the enjoyment of oil or gas rights. These profits, known as 'ring-fence profits,' are subject to an additional 10% supplementary charge. Furthermore, a new Energy Profits Levy has been introduced, applying a 35% tax rate on oil and gas companies' profits from a specified period until March 31, 2028. The EPL does not allow for the offsetting of previous losses or decommissioning costs incurred as of May 26, 2022. However, a new investment allowance has been introduced to incentivize investment in the UK North Sea. This allowance provides 80% relief on qualifying expenditures related to EPL profits. The investment allowance is derived from ring fence capital expenditure and certain ring fence operating expenditure. It results in a total relief of 180% of the amount spent, including 100% First Year Allowances.

An annual tax on enveloped dwellings (ATED) is charged on the acquisition and holding of high-value residential properties (property over GBP 500,000) through a company or other "non-natural" person. The minimum charge is GBP 4,150 for a property valued at GBP 500,000 (minimum value for 2023/24).

A bank levy is applied at 0.1% for short-term chargeable liabilities and 0.05% for long-term chargeable equity and liabilities (does not apply to overseas branches and subsidiaries held by the UK business). The first GBP 20 million or chargeable liabilities is exempt. Bank profits are also subject to a 3% supplementary tax charge on profits above GBP 100 million (reduced from 8% as of April 2023).
Most insurance premiums are taxed at 12% (life assurance and other long-term insurance are exempt).

There are several environmental taxes, including: a Landfill tax, a Climate change levy and an Aggregates levy.

Social security contributions made by the employer amount to 13.8% on all earnings above GBP 175 per week (the first GBP 3,000 being exempt).
Employers are required to pay 0.5% of their total payroll in excess of GBP 3 million to create a fund to support apprenticeships (with an annual allowance of GBP 15,000 to offset against payment of the levy).

The stamp duty land tax (SDLT) is charged in England and Northern Ireland on transfers of real property, with rates varying between 0% and 12% for residential properties (15% if the property is valued at more than GBP 500,000) and 0% to 5% for non-residential properties.
Similar taxes - the land and buildings transaction tax (LBTT) and land transaction tax (LTT) - are charged on Scottish and Welsh property, respectively.
A stamp duty payable by the transferee is charged at 0.5% on instruments effecting sales of shares.

A Digital services tax (DST) is levied at a rate of 2% on the revenues of large businesses that provide a social media platform, search engine, or online marketplace to UK users. The tax applies to companies with an annual turnover above GBP 500 million, of which more than GBP 25 million is linked to the participation of UK users.

A diverted profits tax, at a rate of 31% (25% until 31 March 2023), applies where multinational companies use artificial arrangements to divert profits overseas to avoid UK tax.

Shipping companies can choose to pay tonnage tax in lieu of the normal corporation tax.

For further details, consult the dedicated page on the official governmental portal.

Other Domestic Resources

HM Revenue & Customs

Tax Rate

Allowable Deductions and Tax Credits

Tax relief can be claimed on personal allowances (the standard amount is GBP 12,570 for the 2023-24 tax year, which can be reduced for total income over GBP 100,000, or increased in case of a marriage allowance), work or business expenses and certain pension contributions, charity donations, maintenance payments and time spent working on a ship outside the UK. Contributions for pension schemes can be deducted, provided they respect certain conditions.
Income tax reliefs not subject to a specific restriction are capped at GBP 50,270 or 25% of an individual’s income, whichever is greater.

Necessary business expenses can be deducted from employment income and are not taxable if paid for or reimbursed by the employer.
Expenses that do not qualify for tax relief include: alimony, medical expenses, social security contributions, council tax and other UK taxes, most insurance premiums, mortgage interest payments (some relief for commercially let properties), fines and penalties (except for fines, such as parking penalties, incurred in the course of a trade), contingent liabilities.

For further information, consult the guide of the UK Government.

Special Expatriate Tax Regime

Where an individual is resident and domiciled in the UK, he or she is subject to UK income tax and capital gains tax on worldwide income and gains. Where an individual is resident but not domiciled in the UK, he or she is also subject to UK income tax on worldwide income but may choose to pay tax on foreign income and capital gains on a remittance basis, subject to a supplementary charge. Non-resident individuals are taxed on UK-sourced income and capital gains realized from the disposal of UK residential property.

Residents who are not domiciled or deemed domiciled in the UK may make a claim for the remittance basis of taxation to apply to overseas income, in exchange for an additional tax liability of GBP 30,000 per annum for taxpayers who have been UK residents for seven out of the previous nine tax years, rising to GBP 60,000 once resident for twelve out of the previous fourteen tax years. Click here for more information.
Expatriate allowances are included in taxable income but may be available for exemption for certain subsistence expenses.