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Non-UK entities do not always obviously correspond with UK entity classifications. A number of jurisdictions have legal entities which have no direct UK legal equivalent. For UK tax purposes, it is necessary to determine whether a foreign entity is transparent (like a partnership, where the individual partners are taxed rather than the partnership as an entity itself) or opaque (like a company, which is taxed in its own right).

When a foreign subsidiary is established it is important to consider all the facts and circumstances and, if the position is in any way unclear, consider whether clearance from HMRC on the classification of the foreign entity should be obtained.