On 29 July, the UK government issued a call for evidence in connection with its proposed reform of the UK taxation of carried interest. Noting that the tax treatment of carried interest is the subject of considerable debate,...more
Sovereign immunity is a principle of public international law whereby one sovereign state should not seek to apply its law to another sovereign state. Alongside the jurisdictional immunity foreign sovereigns enjoy in the...more
HM Revenue and Customs (HMRC) published draft legislation on 14 September for inclusion in Finance Bill 2023-24, which will remove the 1.5% charge to UK stamp duty and stamp duty reserve tax (SDRT) with respect to the issue...more
The UK government’s “Growth Plan” (or “mini-budget”), delivered on 23 September, announced that the recent changes to the United Kingdom’s off-payroll working rules will be repealed with effect from April 2023....more
Coinciding with the end of the UK-EU Brexit transition period, the United Kingdom has dramatically reduced the scope of DAC 6 reporting obligations in the United Kingdom. ...more
Businesses in the United Kingdom which engage contractors through intermediaries should prepare now for changes to the “IR35” rules that will take effect in April 2021. ...more
A new act in the United Kingdom provides power to HMRC to claw back coronavirus (COVID-19) support payments and issue penalties for deliberate and inadvertent misuse of such schemes....more
HM Revenue & Customs confirmed on June 25, 2020, that the United Kingdom will adopt a European Union measure to delay the first reporting requirement under EU Council Directive 2018/822, the sixth amendment to the EU...more
HM Revenue & Customs has made available further details to the UK government’s 20 March announcement on a series of initiatives, including a valued added tax deferral, to support British businesses in the face of the...more
HM Revenue & Customs has released guidance setting out temporary changes to its stamping procedure, which will apply for the duration of the coronavirus (COVID-19) measures in the United Kingdom. ...more
The UK government has made a number of announcements that may affect individuals who are UK resident taxpayers, including income tax deferral and statutory sick pay changes, during the coronavirus (COVID-19) pandemic....more
The UK government recently announced a series of further initiatives to support British businesses in the face of the coronavirus (COVID-19) pandemic, including a VAT deferral and business rate holidays....more
The UK government has recently published draft legislation that, from April 2020, will require many private sector businesses engaging self-employed contractors through intermediary service companies to consider whether...more
HM Revenue & Customs has provided a timely reminder of the need for organisations with a connection to the United Kingdom to review their prevention procedures regarding the failure to prevent the facilitation of tax evasion...more
The European Commission (the Commission) published on 2 April a summary of its findings on a state aid investigation into the United Kingdom’s controlled foreign company (CFC) finance company exemption. The Commission has...more
HM Revenue & Customs has released guidance interpreting the UK tax code for individuals dealing in cryptoassets. While most transactions are assumed to be part of investment activities, certain transactions in cryptoassets...more
The UK government seeks representations from stakeholders regarding the design of its proposed “digital services tax,” which would apply to search engines, social media platforms, and online marketplaces, and levy a 2% tax on...more
Does the United Kingdom’s vote to leave the European Union change the United Kingdom’s attractiveness as a holding company jurisdiction?...more
The new exemption from UK withholding tax will affect certain debt finance arrangements and the issuance of debt securities between foreign lenders or investors and UK corporate borrowers or issuers that operate in private...more
The spring budget includes a number of announcements that relate to taxation, the most significant of which is a “roadmap” for UK corporate taxation through 2020....more
The statement is tax light, but there is continued focus on carried interest.
On 25 November, the UK Chancellor of the Exchequer George Osborne made a number of tax-related announcements in the 2015 Autumn Statement and...more
12/1/2015
/ Autumn Statement ,
Common Reporting Standard (CRS) ,
Employee Share Schemes ,
EU ,
FATCA ,
Fund Managers ,
Limited Partnerships ,
Peer-to-Peer ,
Private Equity ,
Stamp Duty Land Tax ,
Tax Avoidance ,
UK
HMRC provides guidance on the implications of the recent case Anson v Revenue and Customs Commissioners.
Delaware limited liability companies (LLCs) are regularly seen in many international corporate groups, including in...more
9/30/2015
/ Anson v HMRC ,
Entity Classification ,
Foreign Tax Credits ,
HMRC ,
Income Taxes ,
Limited Liability Company (LLC) ,
Limited Partnerships ,
Partnerships ,
Tax Treaty ,
UK ,
UK Supreme Court
The new tax announcements are designed to improve productivity and correct imbalances in the tax system.
On 8 July, UK Chancellor of the Exchequer George Osborne made a number of announcements relating to the tax system...more
7/10/2015
/ Amortization ,
Bank Taxes ,
Banking Sector ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Dividends ,
Employment Tax ,
HMRC ,
Income Taxes ,
Loans ,
Peer-to-Peer ,
Resident Non-Domiciled (RND) ,
Tax Legislation ,
UK ,
Value-Added Tax (VAT) ,
Withholding Tax
Announcements support UK growth and prevent tax avoidance.
On 3 December, UK Chancellor of the Exchequer George Osborne made a number of tax-related announcements in the 2014 Autumn Statement. Given the government’s...more
UK government continues to support growth and build on economic recovery.
On 19 March, UK Chancellor of the Exchequer, George Osborne, released the UK’s 2014 budget. From a business tax perspective, the budget...more