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United Kingdom - Deloitte

International Core of Excellence 2016 69per annum per business/group of companies incurred as from 1 January 2016 (GBP 500,000 for the period 1 April 2014 - 31 December 2015).There is a limit on deductions that can be taken for financing costs where UK companies are members of a large group (as defined). These debt cap rules broadly apply where the aggregate tax deductions for net financing costs of UK group companies exceed the worldwide group s gross accounting financing of dividendsA dividend exemption applies to most dividends and distributions unless received by a bank, insurance company or other financial trader. Dividends received by a non-small UK company on most ordinary shares and many dividends on nonordinary shares from another company (UK or foreign) are exempt from UK corporation tax, with no minimum ownership period or minimum ownership level. The exemption also can apply to small companies receiving dividends and distributions from UK companies or foreign companies resident in a jurisdiction that has concluded a tax treaty with the UK which includes a nondiscrimination provision.

United Kingdom Anne-Mari Davidson Director Tel: +1 718 508 6153 anndavidson@deloitte.com David Miles Senior Manager Tel: +1 212 492 3899 damiles@deloitte.com Investment basics Currency Pound Sterling (GBP) Foreign exchange control No Accounting principles/financial statements UK GAAP/IAS. Financial statements must be filed annually.

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