Anti-avoidance measures monitor offshore business

Assuming that an offshore company is properly registered and centrally managed and controlled in an offshore jurisdiction, as discussed in last month's article, what is its tax position regarding the UK? If its beneficial owner is domiciled and resident in the UK, then two anti-avoidance sections immediately bite: the company's income will be assessed on its beneficial owners under the Income and Corporation Taxes Act (ICTA) 1988 section 739 and its capital gains will be assessed under the Taxation of Capital Gains Act (TCGA) 1992 section 13. Section 13 is automatic unless the interest of...