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AIA - UK branch of an overseas company

AIA - UK branch of an overseas company

Hello all,

Second branch related question the day . . . .

Can a UK permanent establishment of an overseas company claim AIA (assuming it isn't used up elsewhere)?  I cannot see anything that suggests no (and presumably it would contravene non-discrimination clauses [parent co is German] if it wasn't available). Reason I have doubt is because a colleague of mine has a 'vague recollection' of AIA not being available.  Also, a claim would take my company from tax paying to not, so I feel like I need concrete evidence either way.

As far as I can see:

- UK branches are allowed any deduction a UK company would be (subject to interest, royalties, non-arms length etc)

- AIA is available to individuals and companies (we are a UK branch of a foreign company, but a company non-the-less)




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24th Feb 2016 16:38

I cannot think of anything that prevents a non-resident company with a UK PE from claiming AIA against its profits liable to corporation tax. I suggest that you tie "vague recollection" person up and beat them until their haze clears.

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