Type Speaker CPD Hours Level
5 IntroductionInformation
Accreditation Information
SRA Competency B


This 5 hour virtual classroom session will review and discuss the principal issues relating to entity recognition for a UK taxpayer.

It is aimed at accountants and tax practitioners whose clients have interests in an overseas entity.

What You Will Learn

This live and interactive session will cover the following:

  • Why does the type of entity matter for UK income tax, CGT, CT, IHT, SDLT purposes?
  • UK tax treatment of transparent and opaque entities
  • When is an entity transparent for UK purposes?
  • When is an entity opaque UK purposes?
  • Importance of foreign legal characterisation and evidence: Rae v Lazard Investment Co Ltd
  • How to answer entity recognition issues - refresher on key cases:
    • Memec plc v HMRC
    • Revenue and Customs Comrs v Anson
  • The provisions of non-UK legislation, articles of association, by-laws, agreement or other document governing the entity’s creation, continued existence and management
  • HMRC’s entity recognition list
  • Nature of interest in foreign entity / ‘shares’ / consequences for UK purposes
  • Tax consequences arising from non-UK entities within corporate holding structures
  • Tax issues relating to ‘Baker’ trusts, Unit Trusts, Limited Partnerships, Scottish Limited Partnerships
  • Tax issues arising on reconstruction and reorganisation of foreign entities by UK taxpayers
  • Return of capital by a foreign entity
  • Double taxation agreements and non-UK entities: residence, double tax relief
  • Stamp duty issues: non-UK situs assets, marketable securities
  • US entities and structures: Check the Box, Delaware entities, Living Wills
  • Tax consequences for foreign entities carrying on business in the UK

Book now

Future dates are coming soon.
Please let us know if you wish to be notified.
Prices (ex VAT)
Plan Information
Ticket Information
Individual licence
Group bookings
Discounts are available for multiple places. If you have 5 or more people interested in participating in this virtual learning session please email us at information@mblseminars.com for more information.

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