About The UK
The UK is the fifth-largest economy in the world, and the second largest in Europe, as measured by the International Monetary Fund (IMF). It is ranked eighth in the World Bank’s Doing Business 2020 report. It is also one of the world's premier financial centres, has a skilled workforce and strong rule of law, and complies with international regulatory standards.
The UK left the EU on 31 January 2020 and a transition period ended on 31 December 2020. The EU-UK Trade and Cooperation Agreement (EU-UK TCA) governing post-Brexit trading terms was signed on 30 December 2020.
The UK is an attractive location for regional treasury centres as it offers one of the world's largest tax treaty networks, with agreements with more than 130 countries. The UK also acts as the world's western hub for renminbi business, while the launch of Shanghai-London Stock Connect gives investors in both locations access to each other’s markets.
In addition, the UK has advanced banking facilities, strong regulation, a broad talent pool and advanced IT and telecoms systems, as well as the world's largest foreign exchange market and the deepest international debt market. More than 300 banks have offices in the UK, primarily in London, with many choosing the city for their headquarters.
Corporate Treasury in The UK
The UK is one of the world’s premier financial centres. Here, we highlight some of the key benefits relevant to treasury and cash management.
Financial Market Development
- The UK is ranked as the second most competitive financial market in the world in the 2021 Global Financial Centres Index by Z/Yen Partners.
- The UK is one of the three key financial centres of the global economy, has a skilled workforce and strong rule of law, and complies with international regulatory standards.
- There are no restrictions on capital flows in and out of the UK.
Sophistication of Banking Systems
- The UK is the largest financial exporter in the world and a leading centre of international finance.
- More than 300 banks have offices in the UK, primarily in London, with many choosing the city for their headquarters. Around half of these banks are incorporated in the UK and half are incorporated outside of it.
- The UK is the largest foreign-exchange market in the world, according to the Bank for International Settlements triennial global survey.
- London offers access to the deepest pool of international capital in the world. There are more than 14,500 debt securities with a value of GBP1.65 trillion listed on the London Stock Exchange Main Market. A total of 1,402 bonds raised GBP514 billion in 2020.
Regulatory Bodies
- The Prudential Regulatory Authority, part of the Bank of England (the central bank), is the prudential regulator of the banking industry in the UK. The Financial Conduct Authority (FCA), which is separate from the Bank of England, regulates the conduct of banks and ensures financial markets work effectively. The regulatory framework is in line with international standards.
Tax
- The corporate income tax rate is 19%, the lowest rate in the G7. The rate will rise to 25% on profits of more than GBP250,000 in April 2023.
- Resident companies are generally taxed on their worldwide income. Non-resident companies pay corporate income tax on income attributable to UK-sourced income and gains on the disposal of UK property, and are subject to income tax at 20% without any allowances.
- Companies may also be liable for diverted profits tax at 25% under certain circumstances.
- There is no branch profits remittance tax on the remittance of profits to a head office by the branch of a foreign company.
- A foreign tax credit is available on tax paid overseas on non-UK-sourced profits against UK tax on the same profits, provided the laws and treaties permit.
- UK companies are exempted from paying corporate income tax on most foreign and UK dividends. Withholding tax of 0% to 20% may be charged on interest, depending on whether a tax treaty is in place and the taxpayer can product a relevant Certificate of Residence.
- Capital gains are generally assessed with ordinary income and subject to corporate income tax. Capital losses can only be offset against capital gains.
- Unrealised exchange gains and losses on debts and derivatives are generally taxed or allowed on an accounts basis.
- There is no safe harbour provision or prescribed debt-to-equity ratio in the UK although companies are expected to transact their business at arm's length. For a UK group, the net interest deduction is limited to 30% of UK tax-EBITDA and it cannot be higher than the net interest as stated in the group’s worldwide consolidated financial statements.
- Stamp duty of 0.5% is charged on the purchase price or value of shares, whichever is higher.
- The standard rate for Value Added Tax (VAT) is 20% on most goods and services. Domestic fuel and power and certain other supplies are charged VAT of 5%. Most exports, foods and other essential goods are zero-rated for VAT.
- The UK has tax treaties with more than 130 countries and territories.
- The UK is a signatory to the Organisation for Economic Co-operation and Development’s Multilateral Competent Authority Agreement, through which information is exchanged between tax administrations, to provide a single, global picture on some key indicators of economic activity within multinational enterprises.
Benefits for Company Treasury Centres and Operations
- The UK has advanced banking facilities, strong regulation, a broad talent pool, and advanced IT and telecoms systems, as well as the world’s largest foreign-exchange market and the deepest international debt market.
- It currently requires that non-resident companies pay corporate tax only on trading profits attributable to a UK permanent establishment. It has one of the world’s largest tax treaty networks, with agreements with more than 130 countries.
- The UK is the second-largest offshore renminbi pool and the RMB centre for Europe.
- Cash concentration is widely available in the UK on a domestic and cross-border basis. Different legal entities can participate in the same cash-concentration structure.
- Notional pooling is allowed in the UK on both a domestic and cross-border basis. Different legal entities can participate in the same notional cash pooling structure.