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What will the UK subsidiary pay in corporation tax?

The headline rates are 19% and 25%. The number that decides which applies is how many companies are under common control — anywhere in the world.

Parent, sister companies, other subsidiaries — worldwide
First periods are often short or long

2025/26 rates: 19% up to £50,000, 25% from £250,000, marginal relief between (fraction 3/200). Limits divided by associated companies + 1 and pro-rated for short periods. Ignores ring-fence profits, non-trading loan relationships and R&D relief. Dormant companies and passive holding companies are not counted as associates.

Corporation tax due

£0

Due nine months and one day after the period end. All the UK taxes a subsidiary pays.

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Why the associated-companies rule matters

Since April 2023 the UK has two corporation tax rates. The small profits rate of 19% applies to profits up to £50,000 and the main rate of 25% from £250,000, with marginal relief smoothing the gap. Those limits are for a standalone company with a twelve-month period.

If the company has associated companies — any company under the same control, in any country, at any point in the period — the limits are divided by the number of associates plus one. A UK subsidiary whose parent has three other subsidiaries has four associates: its limits become £10,000 and £50,000. Almost every subsidiary of an established group therefore pays 25% on all of its profit, and the 19% rate is largely irrelevant to overseas groups.

Dormant companies and pure passive holding companies are excluded from the count. Short first periods pro-rate the limits. Groups with profits above £1.5m (divided the same way) pay in quarterly instalments rather than nine months after the year end.