This section covers the following key areas. Click on a heading below to navigate to that area, you can return to the main menu at any time.

UK tax resident companies

As a UK tax resident company, you are governed by EU and UK legislation and as a result, even if you have no dealings with the EU, Brexit will still have an impact on your business.

If you have dealings with the EU already then this is the time to refresh and reassess the tax and commercial impacts that Brexit will have on your company alongside the challenges or opportunities that Covid-19 has brought. 

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Irish Companies with only UK Directors

An Irish registered company must have at least one EEA resident director. The Irish Companies Registration Office (their version of Companies House) has stated that the UK leaving the EU with no deal would mean that any Irish Company with only UK directors would no longer meet this requirement after a no-deal Brexit.

Please note that this is based on residency, not nationality i.e. an Irish national who is a UK tax resident would not meet this requirement.

It is possible for an Irish company to have no EEA directors, but clearance must be sought and, in some instances, a €2,000 bond must be in place to be renewed and /or paid every two years.

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Supply Chains and Transfer Pricing

Mapping out your supply chain will help identify where potential pressure points may arise as a result of Brexit. If you come across commercial factors that result in either increased or decreased activities in the EU, this may have an impact on your existing transfer pricing. If you are considering moving functions, assets, people or risks to or from the UK post Brexit, please get in touch with your JC adviser to discuss the impact that this will have on your intragroup transactions.

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Withholding Taxes

This is also the time to consider any new withholding tax obligations and costs. Benefits under the EU parent subsidiary directive and the interest and royalties directives, have now gone, however, certain EU countries have brought in temporary measures to delay the impact that this may have on your business. If you receive dividends, interest or royalty payments from the EU, please check with your JC adviser on the potential withholding tax implications. And, if you pay interest or royalties to other companies in EU member states, please speak to your JC adviser, about possible implications this may have.

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Impact on State Aid – Enterprise Management Incentives (EMI)

HMRC has confirmed on 27 October that EMI will be approved under UK Law, so the scheme can continue to operate post 31 December (when state aid approval was due to expire). Excellent news, both for those with a an EMI scheme in place and also those who are seeking to consider potential share incentives. If you have any questions regarding this, we’re here to help. Please contact Andrew.Holloway@jcca.co.uk.

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Key contacts


Susie Walker

Head of Tax and Brexit Team

Susie Walker

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Andrew Holloway

Director, Entrepreneurial Taxes

Andrew Holloway

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Jonathan Russell

International Tax Manager

Jonathan Russell

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