OpenLegislation

Annex

United Kingdom

Original text. Later amendments are not shown.

Note: the numbering of the companies follows the numbering of the annex of the decision to extend proceedings.

For the sake of completeness, the table includes the five contested tax rulings with numbers 83, 84, 139, 140 and 144.

Company NameGranting DateDescription of the activitiesClassification of Ruling (in light of Section 8.2.1)

1.

KaiRo Management Limited

7.1.2011Services, management consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

2.

Thurlestone Shipping (Overseas) Limited

10.1.2011Services, shipping intermediaryApplication of territoriality principle. No income accrued in or derived from Gibraltar.

3.

Mina Corp Limited

10.1.2011Trade, sale of petroleum productsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

4.

Red Star Enterprises Limited

10.1.2011Trade, sale of petroleum productsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

5.

BO (Middle East) Limited

12.1.2011Trade, importation of furnitureApplication of territoriality principle. No income accrued in or derived from Gibraltar.

6.

THE One (Middle East) Limited

12.1.2011Trade, importation of furnitureApplication of territoriality principle. No income accrued in or derived from Gibraltar.

7.

THE One Retail Network (International) Limited

12.1.2011Holding company, licensing intellectual propertyPassive income exemption. Situation regularised after legislative changes or activities ceased.

8.

THE One Music Limited

12.1.2011Trade, manufacture and sale of CDsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

9.

Prospective Company

12.1.2011Holding company, licensing intellectual propertyCompany was not incorporated, activities did not materialise or the company was dormant

10.

Link Holdings (Gibraltar) Limited

14.1.2011Trade, income from rentsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

11.

European Mail Union Limited

28.1.2011Trade, provision of mail forwardingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

12.

Ansellia Aviation Limited

31.1.2011Holding of assets, property (aircraft)Application of territoriality principle. No income accrued in or derived from Gibraltar.

13.

Prospective Company

4.2.2011Beneficiary in a trustCompany was not incorporated, activities did not materialise or the company was dormant

14.

Prospective Company

7.2.2011Provision of loan(s)Company was not incorporated, activities did not materialise or the company was dormant

15.

Zartello Limited

7.2.2011Trade, marketing servicesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

16.

Gol International Limited

10.2.2011Trade, sports agentApplication of territoriality principle. No income accrued in or derived from Gibraltar.

17.

Graf Von Bismark and Associated Limited

21.2.2011Trade, provision of asset managersApplication of territoriality principle. No income accrued in or derived from Gibraltar.

18.

Medifour Limited

25.2.2011Trade, sale of medical productsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

19.

Current Technology (Europe) Limited

25.2.2011Trade, marketingCompany was not incorporated, activities did not materialise or the company was dormant

20.

Corporate Consultants Limited

25.2.2011Services, consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

21.

Alphasol Limited

25.2.2011Services, consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

22.

Akasha Charters Limited

25.2.2011Trade, yacht charteringApplication of territoriality principle. No income accrued in or derived from Gibraltar.

23.

Osato Industries Limited

28.2.2011Services, consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

24.

Gambit Management Services Limited

1.3.2011Holding of property and consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

25.

Greatheart Underwriting Limited

4.3.2011Investment holding companyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

26.

UNILOG, United Logistics & Shipping Operators Limited

9.3.2011Trade, management of shipping lineApplication of territoriality principle. No income accrued in or derived from Gibraltar.

27.

Continental Maritime Limited

15.3.2011Provision of loan(s)Application of territoriality principle. No income accrued in or derived from Gibraltar.

28.

Baby Basics Limited

15.3.2011Trade, marketingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

29.

Baby Basics (Iberia) Limited

15.3.2011Trade, marketing and sales, trainingCompany was not incorporated, activities did not materialise or the company was dormant

30.

Baby Basics (International) Limited

15.3.2011Trade, distribution of productsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

31.

Baby Basics (Asia) Limited

15.3.2011Trade, marketing and sales, trainingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

32.

Family Roots Limited

15.3.2011Trade, marketingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

33.

Western Mediterranean Holdings Limited

16.3.2011Investment holding companyPassive income exemption. Situation regularised after legislative changes or activities ceased.

34.

M. Benady & Company (Gibraltar) Limited

16.3.2011Trade, management servicesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

35.

Prime Ideas Limited

18.3.2011Holding intellectual property rightsPassive income exemption. Situation regularised after legislative changes or activities ceased.

36.

Hattrick Limited

21.3.2011Services, consultancy and advisoryApplication of territoriality principle. No income accrued in or derived from Gibraltar.

37.

Tubingen Limited

22.3.2011Asset holding company, motor yachtApplication of territoriality principle. No income accrued in or derived from Gibraltar.

38.

Channel Energy (Eire) Limited

24.3.2011Trade, storage and handling of petroleumApplication of territoriality principle. No income accrued in or derived from Gibraltar.

39.

Crane Trading Corporation Limited

24.3.2011Trade, motorsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

40.

Europe Income Real Estate Limited

25.3.2011Provision of loan(s)Company was not incorporated, activities did not materialise or the company was dormant

41.

IMAAG Limited

25.3.2011Services, consultancy and advisoryCompany was not incorporated, activities did not materialise or the company was dormant

42.

Prospective Company

28.3.2011Trade, marketing servicesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

43.

Jonsden Properties Limited

28.3.2011Trade, marketing servicesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

44.

Ellise Trading Group Limited

28.3.2011Holding, intellectual propertyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

45.

Kamakura Investments Limited

29.3.2011Investment holdingPassive income exemption. Situation regularised after legislative changes or activities ceased.

46.

Prospective Company

1.4.2011Trade, advertisingCompany was not incorporated, activities did not materialise or the company was dormant

47.

Roxbury Limited

1.4.2011Holding of patents and trademarksPassive income exemption. Situation regularised after legislative changes or activities ceased.

48.

Roger Bullivant Holdings Limited

1.4.2011Group HoldingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

49.

Horizon Ventures Limited

1.4.2011Services, consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

50.

Nidham Holdings Limited

1.4.2011Services, consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

51.

AMD Limited

1.4.2011Trade, sale of agricultural productsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

52.

Cookstown Properties Limited

5.4.2011Holding, company sharesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

53.

Burlington English Limited

7.4.2011Services, consultancy and advisoryCompany was not incorporated, activities did not materialise or the company was dormant

54.

Burlington Marketing Limited

7.4.2011Services, consultancy and advisoryApplication of territoriality principle. No income accrued in or derived from Gibraltar.

55.

Burlington English Limited

11.4.2011Services, consultancy and advisoryCompany was not incorporated, activities did not materialise or the company was dormant

56.

Burlington Marketing Limited

11.4.2011Services, consultancy and advisoryApplication of territoriality principle. No income accrued in or derived from Gibraltar.

57.

Eastcheap Trading Corporation Limited

14.4.2011Provision of loan(s)Application of territoriality principle. No income accrued in or derived from Gibraltar.

58.

Horizon Ventures Limited

14.4.2011Services, consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

59.

Keystone Shipping Limited

4.5.2011Trade, bareboat charteringApplication of territoriality principle. No income accrued in or derived from Gibraltar.

60.

World Rugby League (Europe) Limited

6.5.2011Trade, marketing servicesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

61.

World Rugby League Limited

6.5.2011Trade, marketing servicesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

62.

Lobric Properties Limited

6.5.2011Trade, sale of agricultural productsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

63.

Bushman Limited

6.5.2011Services, consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

64.

Key Retail Technologies Limited

9.5.2011Services, management and consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

65.

Kinsman Trustees Limited

11.5.2011Services, provision of trusteesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

66.

Amicus Trustees Limited

11.5.2011Services, provision of trusteesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

67.

Benamara Limited

11.5.2011Investment holdingPassive income exemption. Situation regularised after legislative changes or activities ceased.

68.

Halstead Investments Limited

11.5.2011Investment holdingPassive income exemption. Situation regularised after legislative changes or activities ceased.

69.

Nightingale Investments Limited

11.5.2011Trade, supply of oil and gas equipmentApplication of territoriality principle. No income accrued in or derived from Gibraltar.

70.

JST (International) Company Limited

11.5.2011Services, consultancy and advisoryApplication of territoriality principle. No income accrued in or derived from Gibraltar.

71.

The Consultants Limited

11.5.2011Services, consultancy and advisoryApplication of territoriality principle. No income accrued in or derived from Gibraltar.

72.

Birchall Properties Limited

17.5.2011Provision of loan(s)Application of territoriality principle. No income accrued in or derived from Gibraltar.

73.

Cookstown Properties Limited

19.5.2011Property and investments holdingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

74.

Paramount Healthcare Consulting Limited

20.5.2011Services, consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

75.

Swerford Holdings Limited

20.5.2011Trade, gamingRuling related to personal income tax and does not involve a company subject to corporate income tax

76.

Orios Limited

23.5.2011Trade, online flower and gift retailerApplication of territoriality principle. No income accrued in or derived from Gibraltar.

77.

Bushman Limited

23.5.2011Services, consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

78.

Nautilus Limited

1.6.2011Asset holding, motor yachtApplication of territoriality principle. No income accrued in or derived from Gibraltar.

79.

Salamba Shipping Limited

1.6.2011Asset holding, motor yachtApplication of territoriality principle. No income accrued in or derived from Gibraltar.

80.

Repset Limited

1.6.2011Group HoldingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

81.

McWane (Gibraltar) Holdings Limited

2.6.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

82.

McWane (Gibraltar) Limited

2.6.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

83.

Heidrick and Struggles (Gibraltar) Holdings Limited.

2.6.2011Provision of loan(s)Contested ruling

84.

Heidrick and Struggles (Gibraltar) Limited.

Limited, GibCo2)

2.6.2011Provision of loan(s)Contested ruling

85.

Walstead Limited

8.6.2011Trade, marketing, sales and researchApplication of territoriality principle. No income accrued in or derived from Gibraltar.

86.

Meritas (Gibraltar) Holdings Limited

8.6.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

87.

Perpetual Systems Limited

9.6.2011Trade in GibraltarRuling related to personal income tax and does not involve a company subject to corporate income tax

88.

Loksys (International) Limited

15.6.2011Trade in GibraltarRuling related to personal income tax and does not involve a company subject to corporate income tax

89.

Lawnsvale Investments Limited

16.6.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

90.

Oilcom Agency Limited

24.6.2011Trade, buying and selling of clothingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

91.

CT Marketing Limited

30.6.2011Services, consultancy and marketingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

92.

Navigia Limited

5.7.2011Services, consultancyApplication of territoriality principle. No income accrued in or derived from Gibraltar.

93.

Ocean Pride Shipping Co. Limited

5.7.2011Asset holding, motor yachtApplication of territoriality principle. No income accrued in or derived from Gibraltar.

94.

Equilibrium Management Limited

11.7.2011Provision of loan(s)Application of territoriality principle. No income accrued in or derived from Gibraltar.

95.

Taylan Limited

11.7.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

96.

Prospective Company

12.7.2011Trade, currency exchangeCompany was not incorporated, activities did not materialise or the company was dormant

97.

Galva Investments Limited

13.7.2011Investment holdingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

98.

Uniphos Limited

13.7.2011Services, consultancy and marketingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

99.

Prospective Company (Advisory Limited)

14.7.2011Provision of loan(s)Company was not incorporated, activities did not materialise or the company was dormant

100.

Prospective company

22.7.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

101.

Prospective company

5.8.2011Trade, marketingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

102.

Hastings Insurance Group Limited

11.8.2011Group HoldingRuling related to personal income tax and does not involve a company subject to corporate income tax

103.

Patron Capital G.P. III Limited

17.8.2011Provision of loan(s)Application of territoriality principle. No income accrued in or derived from Gibraltar.

104.

Vantini Spur Limited

14.9.2011Holding intellectual propertyPassive income exemption. Situation regularised after legislative changes or activities ceased.

105.

Tubman (International) Limited

14.9.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

106.

Tubman (Holdings) Limited

14.9.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

107.

Broadstreet (Gibraltar) Limited

30.9.2011Services, consultancy and loan interestPassive income exemption. Situation regularised after legislative changes or activities ceased.

108.

Biomet (International) Limited

6.10.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

109.

Biomet (Gibraltar) Holdings Limited

6.10.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

110.

Biomet Inc

6.10.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

111.

Biomet S.a.r.l

6.10.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

112.

Waterside (International) Limited

8.11.2011Services, management advisoryApplication of territoriality principle. No income accrued in or derived from Gibraltar.

113.

Prospective Company

International Law Firm)

16.11.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

114.

Infor (Gibraltar) Limited

22.11.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

115.

Miller International Limited

24.11.2011Trade, sale of earth moving productsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

116.

Tipico Services Limited

29.11.2011Services, administrative supportApplication of territoriality principle. No income accrued in or derived from Gibraltar.

117.

Select Sports Management Limited

16.12.2011Services, consultancy football agentApplication of territoriality principle. No income accrued in or derived from Gibraltar.

118.

Allabroad Limited

16.12.2011Trade, sailing tuition and yacht chartersEffectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar

119.

Prospective Company

16.12.2011Services, administrative supportCompany was not incorporated, activities did not materialise or the company was dormant

120.

Delphi Automotive Services (Gibraltar) Limited

20.12.2011Subsidiary companyPassive income exemption. Situation regularised after legislative changes or activities ceased.

121.

8F Leasing (Gibraltar) Limited

22.12.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

122.

8F Leasing S.A.

22.12.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

123.

8F leasing (Bermuda) Limited

22.12.2011Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

124.

Scan Truck & Trailer Rental Limited

3.1.2012Trade, truck and trailer rentalApplication of territoriality principle. No income accrued in or derived from Gibraltar.

125.

Matterhorn Holdings Limited

16.1.2012Trade, Sale of IT materialsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

126.

8F Leasing (Gibraltar) Limited

3.2.2012Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

127.

8F Leasing (Bermuda) Limited

3.2.2012Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

128.

8F Leasing S.A.

3.2.2012Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

129.

8F Leasing (Gibraltar) Limited

20.2.2012Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

130.

8F Leasing (Bermuda) Limited

20.2.2012Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

131.

8F Leasing S.A.

20.2.2012Provision of loan(s)Passive income exemption. Situation regularised after legislative changes or activities ceased.

132.

Zaida Company Limited

2.3.2012Trade, fees and commissions on paymentsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

133.

Rowan Gorilla V (Gibraltar) Limited

29.3.2012Trade, oil well drilling rig (charter)Application of territoriality principle. No income accrued in or derived from Gibraltar.

134.

Rowan Gorilla VII (Gibraltar) Limited

29.3.2012Trade, oil well drilling rig (charter)Application of territoriality principle. No income accrued in or derived from Gibraltar.

135.

Rowan Cayman Limited

29.3.2012Trade, oil well drilling rig (charter)Company was not incorporated, activities did not materialise or the company was dormant

136.

Rowan Drilling (Gibraltar) Limited

29.3.2012Trade, oil well drilling rig (charter)Application of territoriality principle. No income accrued in or derived from Gibraltar.

137.

Rowan Drilling Norway AS

29.3.2012Trade, oil well drilling rig (charter)Application of territoriality principle. No income accrued in or derived from Gibraltar.

138.

Kiluya Employment Management Limited

3.5.2012Services, provision of engineersApplication of territoriality principle. No income accrued in or derived from Gibraltar.

139.

Ash (Gibraltar) One Limited

8.5.2012Subsidiary of chemical companyContested ruling

140.

Ash (Gibraltar) Two Limited

8.5.2012Subsidiary of chemical companyContested ruling

141.

Prospective Company

12.6.2012Holding intellectual propertyCompany was not incorporated, activities did not materialise or the company was dormant

142.

Partner Invest Limited

21.8.2012Trade, company incorporationEffectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar

143.

Partner Invest Limited

21.8.2012Trade, company incorporationApplication of territoriality principle. No income accrued in or derived from Gibraltar.

144.

MJN Holdings (Gibraltar) Limited

11.9.2012Subsidiary in group structureContested ruling

145.

Fidux Trust Company Limited

9.10.2012Trade, provision of trust servicesEffectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar

146.

OED Limited

4.1.2013Trade, software developmentApplication of territoriality principle. No income accrued in or derived from Gibraltar.

147.

Sunbreeze Limited

12.2.2013Trade, online brokerApplication of territoriality principle. No income accrued in or derived from Gibraltar.

148.

Prospective Company

12.4.2013Holding intellectual propertyCompany was not incorporated, activities did not materialise or the company was dormant

149.

Promo 6000 International Limited

22.4.2013Trade, marketing and advertisingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

150.

Visavi 5x5 Limited

22.4.2013Trade, website portalsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

151.

Visavi Activities Limited

22.4.2013Holding company sharesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

152.

Visavi Spins Limited

22.4.2013Trade, website portalsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

153.

Visavi Portals Limited

22.4.2013Trade, website portalsApplication of territoriality principle. No income accrued in or derived from Gibraltar.

154.

Prospective Company

10.5.2013Holding intellectual propertyCompany was not incorporated, activities did not materialise or the company was dormant

155.

Scanlan Worldwide Limited

21.5.2013Trade, buying, importing and exportingApplication of territoriality principle. No income accrued in or derived from Gibraltar.

156.

Rebecca (Holdings) Limited

10.6.2013Provision of loan(s)Application of territoriality principle. No income accrued in or derived from Gibraltar.

157.

IAPA (Global) Limited

24.6.2013Trade, master policy insurance coverApplication of territoriality principle. No income accrued in or derived from Gibraltar.

158.

Collinson Group (Trademarks) Limited

24.6.2013Holding intellectual propertyPassive income exemption. Situation regularised after legislative changes or activities ceased.

159.

Rebecca (Holdings) Limited

28.6.2013Provision of loan(s)Application of territoriality principle. No income accrued in or derived from Gibraltar.

160.

Innophus (Gibraltar) Limited

2.8.2013Trade, industrial manufacturingCompany was not incorporated, activities did not materialise or the company was dormant

161.

Stabalis Limited

22.11.2013Services, provision of consulting intra-group servicesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

162.

J Domains Limited

20.12.2013Services, management of domain salesApplication of territoriality principle. No income accrued in or derived from Gibraltar.

163.

Prospective Company

23.12.2013Trade, supply of merchandiseCompany was not incorporated, activities did not materialise or the company was dormant

164.

Potential immigrant

23.12.2013EmployeeRuling related to personal income tax and does not involve a company subject to corporate income tax

165.

British Virgin Islands Company

23.12.2013Trade, provision of digital products such as online training coursesEffectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar