Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Doors and windows

13 October 2015 / Shimon Shaw
Issue: 4522 / Categories: Comment & Analysis , International

Does income from abroad emanate from a transparent or opaque entity?


  • Determining whether a foreign entity is transparent or opaque can be crucial to determining UK personal tax liabilities.
  • HMRC’s International Manual sets out the departmental tests for transparency.
  • Ascertaining the status of a foreign entity and the nature of distributions from it in advance can avoid unexpected UK liabilities.
  • Although HMRC do list foreign entities this may not include recently created business bodies.
  • Th e tax treatment of the distribution abroad may be critical to determining UK liability.


Opacity and transparency


The question of whether an entity should be looked through so that the beneficial owners are taxed on its income is a fundamental issue and thankfully it is fairly straightforward for most UK practitioners to grasp....

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon