50%/35% (for chargeable periods ending after 31 December 2015)
Branch tax rate 20% (from 1 April 2015, previously 21%)
Capital gains tax rate 0%/20% (from 1 April 2015, previously 21%)
Basis Worldwide, subject to election for branch exemption
Participation exemption Yes

− Carryforward Indefinite − Carryback One year
Double taxation relief Yes
Tax consolidation No, but loss relief is available and assets can be transferred intragroup without
crystalizing a gain or loss
Transfer pricing rules Yes
Thin capitalization/interest restriction rules Yes
Controlled foreign company rules Yes

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